Comment Analysis · Docket FS-2025-0001

FS-2025-0001-328149

Opposes rescissionA1 strongSubstance 16/24Owed an answerPosted September 7, 2026 On Regulations.gov

In short: The comment places on the record a specific deficiency in the agency's analysis by citing the 2001 beneficial-effect finding for listed species and a 2026 peer-reviewed study on ignition density to argue that the DEIS fails to explain the departure from prior findings or support its fire-risk statistics with cited data and methodology.

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

A1 strong: Must be answered — it names the law.

Owed an answer on Analytical gap, Legal.

Standard dismissals it defeats

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.
Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
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.

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.
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.
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.

Topics

Recreation Tourism Public Use
- “innumerable opportunities for hiking, backpacking, fishing, hurting, paddling, whitewater rafting”
- “source of recreation for humans that will never be able to be replaced”
- “lose access to the beauty of areas where I regularly hike and spend time on the river”
- “drawn by their peace and quiet”
Environmental Protection Biodiversity
- “loss of habitat for plants and animals”
- “risking the lives and well being of countless species of plants and animals who call it home”
- “prohibitions on road construction and timber harvest were not likely to adversely affect threatened or endangered species”
- “may beneficially affect threatened, endangered, and proposed species and critical habitat”
Forest Management Wildfire
- “claim that this action would reduce fires”
- “77 percent and 74 percent were reported as naturally ignited in wilderness areas”
- “ignition density highest within 50 meters of roads”
- “evidence directly bearing on whether expanded road access would increase, not decrease, fire risk”
Legal Regulatory Framework
- “must show that there are good reasons for the new policy”
- “FCC v. Fox Television Stations, 556 U.S. 502, 515 (2009)”
- “Organized Village of Kake v. USDA, 795 F.3d 956, 966–68 (9th Cir. 2015)”
- “Blue Mountains Biodiversity Project v. Blackwood, 161 F.3d 1208 (9th Cir. 1998)”

What it names

Law cited: 161 F.3d 1208 161 F.3d 1208 556 U.S. 502 795 F.3d 956

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapEvidenceLegal

To the U.S. Forest Service: I have grown up in an area surrounded by wilderness protected by the Roadless Rule. These lands are a huge draw for people to visit and live in the area as they provide innumerable opportunities for hiking, backpacking, fishing, hurting, paddling, whitewater rafting, and just spending a day by the river or in the woods alone. Rescission of this rule would cause a loss of habitat for plants and animals and a source of recreation for humans that will never be able to be replaced I have spent 33 years in these forests protected by the Roadless Rule, they are precious to me and many people I know. As a 9 year old with my family, I backpacked 35 miles of the Foothills Trail which introduced me to the wild beauty of the wilderness of Upstate South Carolina. We planned this 3 day trip specifically to connect with nature and each other, away from "real" life and its distractions. If this rule was rescinded, I would lose access to the beauty of areas where I regularly hike and spend time on the river (or those areas would be degradated as a consequence). My 80 year old father also spends the equivalent of weeks out there each year, drawn by their peace and quiet. We are risking the loss of connection to ourselves by rescinding this rule, as well as risking the lives and well being of countless species of plants and animals who call it home. “In 2001 the Agency Found These Prohibitions Benefited Listed Species; the Rescission Never Engages Its Own Prior Finding Both Draft Biological Assessments open with the same acknowledgment (USFWS BA p. 10; NMFS BA p. 7): "In the promulgation of the 2001 Roadless Rule, the Forest Service found that the Rule's prohibitions on road construction and timber harvest were not likely to adversely affect threatened or endangered species or adversely modify designated or critical habitat; were not likely to jeopardize proposed species or adversely modify proposed critical habitat; and may beneficially affect threatened, endangered, and proposed species and critical habitat… The Services concurred with the determination." The agency thus stands on a concurred-in finding that the prohibitions it now proposes to delete benefit listed species — and the current assessments anticipate widespread adverse effects from deleting them. When an agency reverses course, it "must show that there are good reasons for the new policy," FCC v. Fox Television Stations, 556 U.S. 502, 515 (2009), and where the prior policy rested on factual findings, it may not simply disregard them — the principle applied to this very rule's Tongass history in Organized Village of Kake v. USDA, 795 F.3d 956, 966–68 (9th Cir. 2015) (en banc). Neither the DEIS nor the assessments explain what changed in the biology. I request the FEIS directly address the 2001 beneficial-effect finding and state the factual basis for departing from it.” “On the topic of the Forest Service's claim that this action would reduce fires: The Draft EIS reports that "77 percent and 74 percent were reported as naturally ignited in wilderness areas and potentially affected IRAs, respectively," while "the majority (57 percent) of fires with cause determinations on other NFS lands were reported as human caused" (Environmental Impacts, Wildfire Occurrence section), yet no dataset or cause-determination methodology is cited to support either figure. These percentages materially qualify the fire-risk rationale for opening IRAs to road construction, since a peer-reviewed 2026 study found ignition density highest within 50 meters of roads (7.99 fires/1000 ha) and lowest in wilderness and roadless areas (1.75 and 1.97 fires/1000 ha respectively) — evidence directly bearing on whether expanded road access would increase, not decrease, fire risk. Did the agency consider this or comparable ignition-density research, and if so, where does the record explain its rejection? An agency must rely on accurate, disclosed data rather than unsupported statistics. Blue Mountains Biodiversity Project v. Blackwood, 161 F.3d 1208 (9th Cir. 1998). I request the agency cite its fire-occurrence dataset and cause-determination methodology and reconcile it with contrary ignition-density findings.” The Department should keep the Roadless Rule in place. I think the record supports that, and so does the public. Respectfully submitted, CommentID: RLC-20260904-JTO8PV