Comment Analysis · Docket FS-2025-0001

FS-2025-0001-324187

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

  • Environmental Protection Biodiversity
    • “degrade habitat quality”
    • “Direct habitat conversion and indirect fragmentation”
    • “keep nature wild”
    • “maintaining the federal protection for roadless areas”
  • Recreation Tourism Public Use
    • “outdoor enthusiast who regularly uses areas”
    • “retain their current character”
    • “public lands belong to the people”
  • Governance Policy Process
    • “Department's obligation under applicable statutes”
    • “giving full weight to the public interest”
    • “Not a fan of this proposal. Pull it.”

What it names

National Forests
Green Mountain and Finger Lakes National Forests
Roadless areas
Woodford 09086
Works cited
10.1186/1735-2746-10-23

Attachments

1 file. Counts as 1 — Counts as one: The attachments enclose no one else's submissions; the comment counts as one.

  • Own letter

The comment

Dear Secretary: As an outdoor enthusiast who regularly uses areas of national forest that retain their current character specifically because the 2001 Rule prohibits road construction within them, I respectfully submit that the Department's obligation under applicable statutes includes giving full weight to the public interest in those conditions before authorizing their alteration. Regarding the Woodford 09086 in the Green Mountain and Finger Lakes National Forests, Vermont: These public lands belong to the people and it is our job to protect them, including maintaining the federal protection for roadless areas. It's imperative we keep nature wild. Timber harvest, associated road construction, and vegetation removal directly alter roadless character and degrade habitat quality. Forest road construction damages adjacent trees. Road construction on steep mountain terrain damages 21 to 33 percent of trees in the construction zone, depending on equipment used; on very steep terrain, damage rises to 27 to 44 percent. Direct habitat conversion and indirect fragmentation extend well beyond the road's physical footprint (Caliskan 2013). — Caliskan, 2013 (https://doi.org/10.1186/1735-2746-10-23) Rescinding the Roadless Rule would open the Woodford 09086, Green Mountain and Finger Lakes National Forests to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. Not a fan of this proposal. Pull it. With thanks, Delia O'Donnell

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