Comment Analysis · Docket FS-2025-0001

FS-2025-0001-343897

Opposes rescissionA2 moderateSubstance 11/24Owed an answerPosted September 12, 2026 On Regulations.gov

Campaign — One letter sent by 10 or more people, copied or lightly reworded. One of 18 submissions in its group; the sender added words of their own. See the letter, its submissions and topics.

In short: The comment establishes that the agency failed to adequately assess the reasonably foreseeable national and regional environmental effects of rescinding the 2001 Roadless Area Conservation Rule, specifically regarding landscape fragmentation, habitat connectivity, and watershed threats, and requests that the No Action Alternative be selected to keep the Rule intact.

Scored with own additions — A family member whose own text beyond the shared letter was scored and combined with the letter's score.

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

A2 moderate: Hard to dismiss — it shows cause and effect.

Owed an answer on Analytical gap.

Standard dismissals it defeats

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.

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.
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.
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
- “intact forests”
- “habitat connectivity”
- “native plants and invasive species”
- “landscape fragmentation”
Water Quality Quantity
- “clean water”
- “threaten watersheds and drinking-water sources”
- “regional watersheds”
Tribal Sovereignty
- “Tribal consultation remains incomplete”
- “Tribal concerns about subsistence”
- “cultural resources”
Governance Policy Process
- “select the No Action Alternative”
- “Deferring NEPA review to future site-specific individual projects”
- “not adequately assessed the reasonably foreseeable national and regional environmental effects”

What it names

National Forests: Tongass National Forest

The comment

Secretary Brooke Rollins Thomas Schultz Chief, U.S. Forest Service Re: Docket No. FS-2025-0001 - Comments on the 2001 Roadless Area Conservation Rule Dear Secretary Rollins and Chief Schultz: I am writing to ask that USDA keep the 2001 Roadless Area Conservation Rule intact, select the No Action Alternative, and revise the DEIS. Every generation is responsible for protecting our lands for future generations. The current Rule allows substantial forest management, including prescribed fire and other hazardous-fuels reduction. While USDA claims rescission would reduce wildfire risks, the DEIS cites research that 1) the lack of roads has not prevented fire prevention or protection measures, and 2) acknowledges that almost 90% of wildfires are human caused and more than four times likely to ignite near a road. If specific constraints exist, USDA should identify and address those narrow constraints rather than remove the Rule’s nationwide protections. USDA has not adequately assessed the reasonably foreseeable national and regional environmental effects of its decision to eliminate the Rule’s protections across 44.7 million acres of public lands. Deferring NEPA review to future site-specific individual projects will not address the regional and national consequences of rescission. While later reviews may evaluate individual projects, they would not address foreseeable programmatic impacts at scale from landscape fragmentation, habitat connectivity, native plants and invasive species. interstate or inter-forest migration corridors, or regional watersheds. USDA should assess now where national rescission would put intact habitat, wildlife movement, and native plant communities at greatest risk, and where added roads and timber harvest could most threaten watersheds and drinking-water sources. Rescission would also remove protections from 9.3 million acres in the Tongass National Forest, relying on the 2020 Alaska Roadless Rule Final EIS, but it has not demonstrated the earlier environmental analysis adequately evaluates rescission. Tribal consultation remains incomplete. USDA should fully consider Tribal concerns about subsistence, cultural resources, fish and wildlife, and intact landscapes before making a final decision. I ask that you please keep the national protections of the Rule in place and reassess the reasonably foreseeable effects now.