Comment Analysis · Docket FS-2025-0001

FS-2025-0001-327447

Opposes rescissionA0 noneSubstance 4/24Posted 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
- “ecologically-intact, unfragmented habitat for for wildlife such as elk and mule deer”
- “Nature is largely “left alone” to simply be what it is without human interference”
- “insects, mammals, birds, fish, and more to live, forage for food, mate, and raise their young in a protected space”
Forest Management Wildfire
- “studies show that wildfires are four times more likely to start in areas with roads than in roadless forest tracts”
- “A whopping 90% of wildfires start within half a mile of a road”
- “collaborated with partners and performed cultural and prescribed burns... reducing the fuel load”
Water Quality Quantity
- “Roadless forests, river and stream ecosystems, and other wilderness, are key to clean drinking water”
- “These are important watersheds that millions of people rely on”
- “pure air and water”
Recreation Tourism Public Use
- “lifetime - over 60 years now - of hiking, camping, and taking road trips to and within forests and parks”
- “iconic scenery and trails like the Pacific Crest Trail, drawing recreationists, anglers and hunters”
- “widely supported by stakeholders in the outdoor recreation industry, outdoor enthusiasts”

What it names

Roadless areas: Santa Cruz

The comment

I am writing to urge the Forest Service to keep the 2001 Roadless Rule fully intact going forward, as it not only helps reduce wildfires but has many other important benefits as well. I care about this because I value having protected areas where Nature is largely “left alone” to simply be what it is without human interference. Amazing scenery, wildlife going through its natural life cycles, pure air and water. . . these not only have a right to exist, they also help us humans thrive too as part of the interconnected web of life. Beyond this, I have a lifetime - over 60 years now - of hiking, camping, and taking road trips to and within forests and parks across the country. These are memorable, lifetime “WOW!” experiences. My reasons for supporting the Rule are many. First and foremost: studies show that wildfires are four times more likely to start in areas with roads than in roadless forest tracts. A whopping 90% of wildfires start within half a mile of a road. The Roadless Rule provides ecologically-intact, unfragmented habitat for for wildlife such as elk and mule deer. It allows the living beings of the natural world - insects, mammals, birds, fish, and more to live, forage for food, mate, and raise their young in a protected space without the constant disruption of invasive human activity. Roadless forests, river and stream ecosystems, and other wilderness, are key to clean drinking water as well. These are important watersheds that millions of people rely on. These wilderness areas include some of the best game and cold-water fish habitat, plus iconic scenery and trails like the Pacific Crest Trail, drawing recreationists, anglers and hunters, and more. Further economic facts include but are not limited to these points: most logging in easily-accessed forest already has been cut down. Roads into wilderness are expensive to maintain and cost taxpayers up to $500,000 per mile due to the rugged terrain. The Roadless Rule has been widely supported by stakeholders in the outdoor recreation industry, outdoor enthusiasts, conservationists, state game and fish agencies, and elected officials. When the First Service first developed this Rule in 1999, it encouraged huge public participation in the rulemaking process, holding over 600 public meetings across the US. More than 1.6 million people submitted comments, with 95% of them supporting roadless area protection. The Roadless Rule remains popular today. I would like to make a different suggestion for helping to maintain the health of our wilderness areas: I would like to see greater collaboration/partnerships with and empowerment of indigenous Native American tribes, which would include their stewardship of these wilderness areas and their historic, cultural practices. These groups are connected to these lands in a way that other people are not: they have history and knowledge of co-existing with these lands for millennia. Their wisdom is key at this juncture in our history. An example of how indigenous wisdom and practices benefit: I live in California, near where the CZU Lightning Complex fires burned so hotly in and around Santa Cruz in 2020. Parks such as Big Basin State Park were severely damaged. Prior to this blaze, the Amah Mutsun Tribal Band indigenous to this area collaborated with partners and performed cultural and prescribed burns in San Vicente Redwoods park, reducing the fuel load. The result: while the CZU fires burned across the entire San Vicente property, the forest there has been more resilient than other nearby forests and parks. Again, I urge you to keep the Roadless rule in place. It is doing its job. It is important. The People want it. Thank you.