Comment Analysis · Docket FS-2025-0001

FS-2025-0001-313393

Opposes rescissionA0 noneSubstance 6/24Posted September 4, 2026 On Regulations.gov

Scored directly — The comment's whole text was scored on its own.

Scorecard

Each dimension is scored 0–3; the eight sum to the substance score out of 24.

  • Specific placeNames a specific location — from a region down to an exact creek, trail, road, or map reference.
  • Local knowledgeDraws on a first-hand connection to the place — visits, sustained activity, occupation, or a professional role.
  • EA analysisEngages the agency's environmental analysis directly.
  • Analytical gapIdentifies something the analysis fails to address.
  • EvidenceBacks claims with specific facts, data, or research.
  • RequestMakes a specific, actionable request of the agency.
  • AlternativeProposes a different course of action.
  • LegalCites statutes, regulations, or legal obligations.

How hard it is to set aside

A0 none: Counted, not answered.

Still open to the agency

  • Alternative already eliminated The agency says it considered and eliminated the alternative the comment proposes, with a reason. Cannot be defeated from the comment text alone.
  • Already addressed The agency says its analysis already covers the point. Defeated when the comment cites the law itself: there is no analysis to cite against a statutory claim.
  • Deferred to a later decision The agency says the point belongs to a later, site-specific decision. Cannot be defeated from the comment text alone.
  • Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
  • Not required The agency says the analysis the comment asks for is not required. Cannot be defeated from the comment text alone.
  • Preference noted The agency notes the comment as a statement of preference and takes no action on it. Cannot be defeated from the comment text alone.
  • No cause and effect shown The agency says the comment asserts a harm without showing how the action causes it. Defeated when the comment shows the mechanism.
  • Outside the scope The agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.
  • Certified not substantive The agency certifies the comment raises nothing substantive. Defeated when the comment alleges illegality, which is substantive by the definition the certification runs on.

Topics

  • Environmental Protection Biodiversity
    • “habitat fragmentation”
    • “intact ecosystems”
    • “disrupt wildlife habitat and migration corridors”
  • Water Quality Quantity
    • “degradation of watersheds and drinking-water sources”
    • “clean water”
    • “introduce erosion and other threats to watersheds”
  • Recreation Tourism Public Use
    • “diminish the solitude and sense of wildness”
    • “opportunity to experience wild country largely undisturbed”
    • “essential opportunity for reflection, renewal, personal growth”
  • Forest Management Wildfire
    • “concerned by arguments that additional roads are necessary to reduce wildfire risk”
    • “create new opportunities for human-caused fires”
    • “nearly two-thirds of human-caused fires... occurred along roadsides”

What it names

National Forests
Umatilla National Forest

The comment

I am a lifelong hiker and outdoorswoman who cares deeply about the protection of our national forests. I strongly support the 2001 Roadless Area Conservation Rule and Alternative 1 No Action in the Draft Environmental Impact Statement, which would continue management of our national forests under the existing Roadless Rule. I am adamantly opposed to Alternative 2 Proposed Rule, which would fully rescind these protections and leave some of our nations most intact forest lands more vulnerable to road construction, habitat fragmentation, degradation of watersheds and drinking-water sources, and commercial development. These protections matter to me not only as a matter of conservation policy, but from personal experience. In the spring and summer of 2026 alone, I was fortunate to spend months hiking through public lands across the West, including sections of the Pacific Crest Trail in California and Washington, Oregons Eagle Cap Wilderness, and the Umatilla National Forest. Traveling on foot through remote landscapes has given me a profound appreciation for what roadless areas preserve: intact ecosystems, wildlife habitat, clean water, solitude, and the increasingly rare opportunity to experience wild country largely undisturbed by roads and commercial activity. Those experiences would be fundamentally different if these landscapes were fragmented by new roads and logging operations. Roads do more than provide access; they permanently change the character of a landscape, disrupt wildlife habitat and migration corridors, introduce erosion and other threats to watersheds, and diminish the solitude and sense of wildness that draw millions of Americans to our national forests. I am also concerned by arguments that additional roads are necessary to reduce wildfire risk. While roads can provide firefighters with access after a fire begins, they also bring more people and more potential ignition sources into previously remote areas. Forest Service research found that nearly two-thirds of human-caused fires in the Southern California national forests studied occurred along roadsides. Expanding road access into currently roadless areas may therefore create new opportunities for human-caused fires even as proponents argue that those same roads are needed to fight them. There is also a basic question of fiscal responsibility. The Forest Service already manages approximately 380,000 miles of roads nationwidemore than the U.S. highway systemand Washington Trails Association reports that the agency has only about 15 percent of the funding necessary to maintain those roads adequately. Anyone who regularly hikes in our national forests has seen the consequences: potholes, washouts, deteriorating surfaces, and roads that eventually become impassable. Building additional roads without providing substantial new and sustained resources to maintain them is not responsible forest management. It simply adds more infrastructure to a system the Forest Service is already struggling to maintain. Rather than extending this maintenance burden into our remaining roadless areas, we should invest limited resources in maintaining and restoring the roads we already have. For me, time in wild places is not simply recreation. It provides an essential opportunity for reflection, renewal, personal growth, and connection with the natural world. I am one of countless Americans who value our national forests for these reasons, and these lands belong not only to those of us who enjoy them today but also to generations who have yet to experience them. Once an intact roadless landscape is fragmented, we cannot easily recreate what has been lost. I therefore urge you to protect the 2001 Roadless Area Conservation Rule, support Alternative 1 No Action, and oppose any effort to rescind these longstanding protections. Please preserve our remaining roadless national forest lands and the ecological, recreational, and deeply human values they provide.

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