Comment Analysis · Docket FS-2025-0001

FS-2025-0001-317558

Opposes rescissionA0 noneSubstance 6/24Posted September 7, 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

  • Wildlife Habitat
    • “wildlife habitat for those species that need large swaths of older timber”
    • “fragmentation of habitat”
    • “wildlife habitat, and undeveloped-land benefits”
  • Water Quality Quantity
    • “watershed protection for public water supplies”
    • “aquatic species habitat”
  • Environmental Protection Biodiversity
    • “rare plant habitats”
    • “non-native invasive species”
    • “mature to old growth forests”
  • Forest Management Wildfire
    • “Wildfire risk is low in most of these areas”
    • “increased risk of human-caused ignitions”
    • “fires could be let burn, assisting fire-dependent species”

What it names

National Forests
Ottawa National ForestTongass National Forest

The comment

I am writing to oppose the proposal by the US Forest Service to rescind the 2001 Roadless Area Conservation Rule, which established broad prohibitions on road construction, road reconstruction, and timber harvesting within inventoried roadless areas on National Forest System lands. I am a retiree from the US Forest Service after over 30 years, and have worked on the Tongass NF, the Ottawa NF and for the Eastern Region as a detailer. I am well aware of the roles played by the lands protected from road and other development and timber harvest under the Roadless Rule, which include wildlife habitat for those species that need large swaths of older timber without vehicles; watershed protection for public water supplies and aquatic species habitat; rare plant habitats; and more. There is no shortage of harvestable timber that would require these areas to be opened, many sales in my area (Ottawa, Hiawatha, Chequamegon-Nicolet NFs) are not even bid on and the mills can't take on more work or get a good price. There is already plenty of access for the public to national forests without adding roads to these areas, and there is a backlog of road maintenance needs such that opening the area to more roads is unnecessary and unaffordable. Wildfire risk is low in most of these areas without vehicles or logging equipment causing ignitions, and there are no structures to protect such that in fire-associated habitats, fires could be let burn, assisting fire-dependent species. New roads bring multiple hazards: non-native invasive species (for which the treatment costs are already very high), fragmentation of habitat, and increased risk of human-caused ignitions. Roadless areas often connect across forests such that national/big picture analysis is needed to fully define cumulative effects. The current administration has already taken aim at so many of our public lands-reducing the size of parks and monuments; eliminating staff at all the land management agencies; handing public land to private entities. The Roadless Rule must stay in place to prevent further damage to our wildland heritage, mature to old growth forests, wildlife habitat, and undeveloped-land benefits. There is no compelling reason to open these lands! Thank you for your consideration.

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