Comment Analysis · Docket FS-2025-0001

FS-2025-0001-345004

Opposes rescissionA0 noneSubstance 5/24Posted September 12, 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

Wildlife Habitat
- “fragment wildlife habitat”
- “support native fish, including Arizona's unique native trout”
- “mammals, birds, amphibians, reptiles, insects, plants, and fungi”
- “intact roadless landscape”
Water Quality Quantity
- “protect soils, influence runoff, maintain water quality”
- “put even more stress on watersheds already dealing with drought”
- “increase erosion and sedimentation”
- “support streams and springs”
Environmental Protection Biodiversity
- “introduce invasive species”
- “A lot of this biodiversity is directly connected to the health of these watersheds”
- “remote canyon ecosystems”
- “relatively undisturbed by permanent infrastructure”
Governance Policy Process
- “protections should remain federal and provide a consistent national standard”
- “protection of nationally owned public lands should not depend entirely on changing local political or economic priorities”
- “Local input should remain part of National Forest management”

What it names

National Forests: Apache-Sitgreaves National Forests
Works cited: Andrews et al. 2015

Attachments

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

Own letter
Own letter
Own letter
Own letter

The comment

I strongly oppose rescinding the 2001 Roadless Area Conservation Rule. I believe these protections should remain federal and provide a consistent national standard for protecting the remaining inventoried roadless areas. I live in Arizona, and the more I have learned about the ecology of our National Forests, particularly the Blue Range, White Mountains, and Apache-Sitgreaves National Forests, the more important I think these protections are. Roadless areas are unique because they have remained relatively undisturbed by permanent infrastructure. New roads can fragment wildlife habitat, increase erosion and sedimentation, introduce invasive species, and increase access to previously remote areas. Once these landscapes are fragmented, reversing those effects can be extremely difficult. I am also concerned about what increased road construction and intensive logging could mean for watersheds throughout the drought-prone West. Relatively undisturbed forest watersheds protect soils, influence runoff, maintain water quality, and support streams and springs. Additional road construction, soil disturbance, and vegetation removal can put even more stress on watersheds already dealing with drought, increasing temperatures, and severe wildfire. Eastern Arizona is a good example of what could be affected. The Blue Range, White Mountains, Black River, and surrounding watersheds contain high-elevation forests, isolated streams, riparian habitats, and remote canyon ecosystems. They support native fish, including Arizona’s unique native trout, along with mammals, birds, amphibians, reptiles, insects, plants, and fungi. A lot of this biodiversity is directly connected to the health of these watersheds. I understand that forests still need to be managed. Restoration, wildfire mitigation, and other necessary work can already occur under exceptions to the Roadless Rule. I do not see that as a reason to remove the federal protection entirely. Local input should remain part of National Forest management, but protection of nationally owned public lands should not depend entirely on changing local political or economic priorities. Once an intact roadless landscape is lost, recreating it is extremely difficult. I ask the Forest Service to retain the 2001 Roadless Area Conservation Rule and continue federal protection of Inventoried Roadless Areas.