Comment Analysis · Docket FS-2025-0001

FS-2025-0001-329788

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
    • “fails to appropriately assess the impacts this would have on countless unique ecosystems”
    • “endemic salamander species that should clearly be of top concern”
    • “cause rare or endangered species to go extinct”
    • “irreversibly damage critical ecosystems”
  • Water Quality Quantity
    • “contaminating drinking water”
    • “headwaters of the James are protected and kept clean and healthy by Roadless Areas”
    • “critical drinking water protections”
    • “threat to her drinking water”
  • Recreation Tourism Public Use
    • “tourism for hiking, camping, and similar outdoor activities is one of the main economic forces”
    • “loss of scenic beauty and joy from her home”
    • “opening these areas to roads, logging, and mining could... destroy the mountain ecosystems”
  • Economic Impact Fiscal
    • “huge cost of road building”
    • “livelihoods of thousands of people and the vitality of the towns themselves”
    • “profits of which are shipped overseas or into the coffers of already ultra-wealthy corporations”
    • “US taxpayers often do not benefit much from road building and logging”

What it names

National Forests
George Washington National ForestWhite Mountain National Forest

The comment

To the United State Forest Service and Department of Agriculture, The proposal to repeal the Roadless Area Conservation Rule is the wrong decision and should not be finalized. The Roadless Rule protects tens of millions of acres of land across the country, and the broad proposal to repeal the rule – and the alternative to heavily modify it – fails to appropriately assess the impacts this would have on countless unique ecosystems. Repealing Roadless Rule protections for a given area must only be done after careful scientific analysis of whether the ecosystem can withstand road building and resource extraction without irreparable damage to human wellbeing or species survival. Each individual Roadless Area must be assessed, which this proposal and accompanying DEIS utterly fails to do. Two adjacent Roadless Areas may have very different characteristics, and a careful analysis of each is necessary to ensure we do not irreversibly damage critical ecosystems, cause rare or endangered species to go extinct, or threaten human wellbeing through actions like contaminating drinking water. In Virginia, some Roadless Areas in the George Washington National Forest are home to endemic salamander species that should clearly be of top concern for maintaining roadless protection. A complete repeal of the Roadless Rule provides no security to ensure critical Roadless Areas remain protected, and instead opens every single area to potentially catastrophic human activity. Other Roadless Areas in Virginia are important for protecting drinking water. Millions of Virginians rely on the James River for drinking water, and the headwaters of the James are protected and kept clean and healthy by Roadless Areas. Many other Roadless Areas across the country have this same benefit. Repealing or heavily modifying the Roadless Rule without examining each Area with critical drinking water protections to ensure they remain protected and do not cause a public health crisis for millions of Americans is unacceptable. Another important reason to keep the Roadless Rule in place is that it provides economic benefit across the country. In the White Mountain National Forest in New Hampshire, tourism for hiking, camping, and similar outdoor activities is one of the main economic forces for many nearby towns, such as Gorham and Conway. Opening these areas to roads, logging, and mining could not only destroy the mountain ecosystems, but the livelihoods of thousands of people and the vitality of the towns themselves. Another economic factor against repealing the Roadless Rule is the huge cost of road building. The US Forest Service already has a massive backlog of projects it does not have the money, nor the manpower, to complete. Opening millions more acres to roadbuilding will make this problem grow exponentially, causing further delays in places already open to roads. Another point is that US taxpayers often do not benefit much from road building and logging in National Forests. The government often builds roads with taxpayer dollars, but the roads are then used by private companies for logging or mining, the profits of which are shipped overseas or into the coffers of already ultra-wealthy corporations and billionaires. Instead, we lose our public forests, harm our air and water, threaten species survival, and receive nothing in return. The Forest Service must pay more attention to how Americans will actually be impacted—not a few huge corporations, wealthy individuals, and foreign buyers, but the average American. An elderly person living on Social Security and Medicare in rural Virginia. My grandmother is such a person, and the evidence shows me the impact on her will be a threat to her drinking water, a loss of scenic beauty and joy from her home, and the potential disappearance of the wildlife she loves so much. She will not receive a single dollar of financial benefit. Nor will she receive any significantly increased protection from wildfire. The Roadless Rule already has exceptions for necessary fire fighting, and building roads and resource extraction into Roadless Areas is very likely to increase fire risk, something the Forest Service does not examine in enough depth before proposing to open over 40 million acres to new road projects. In conclusion, repealing or even heavily modifying the Roadless Rule is a decision with detrimental effects of great but unknown magnitude. More attention must be paid to all of the things I mentioned, at a locally specific level, not a whole National Forest or the level of the whole country. Each Area needs its own assessment before its protections are removed, or we are sure to lose species, destroy vital ecosystems, ruin local economies and towns, and cause illness and death to people. Please reconsider your proposal and keep the critical protections of the Roadless Area Conservation Rule in place. Sincerely, Connor Ransom Bumpass, VA 23024

Keep learning. Keep speaking up.The Roadless Rule depends on public engagement. Share what you've learned.

© 2026 roadless.org - Defending America's Last Wild Forests

Privacy Policy|Questions or concerns? noroads@roadless.org|Follow us: @defendroadless