Comment Analysis · Docket FS-2025-0001

FS-2025-0001-352602

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

  • Water Quality Quantity
    • “largest loss of protections for rivers on federal lands”
    • “headwaters of some of the nation's most critical drinking water sources”
    • “helping ensure clean drinking water for more than 25 million Americans”
    • “significant protection for rivers, clean water”
  • Wildlife Habitat
    • “protecting fish and wildlife habitat”
    • “walked up on wolf pups”
    • “greeted a mother black bear and two cubs”
    • “sprung bull moose”
  • Recreation Tourism Public Use
    • “experience the the wonder that lies in the depths of our public lands beyond the end of a road”
    • “avid outdoor enthusiast, adventuring by foot, by bike, by packraft, and by rope”
    • “opportunity to experience what lies beyond the “end of the road” throughout their lives”

What it names

National Forests
Lassen National Forest

The comment

Dear Special Areas: Roadless Area Conservation, Dear As a former U.S. Forest Service Hydrologic Technician across 5 National Forests in Washington, Oregon, Idaho, South Dakota, and California, I've experience the the wonder that lies in the depths of our public lands beyond the end of a road more than many of my fellow citizens. I've walked up on wolf pups in Washington, had a 200lb mountain walk up on me in Oregon, greeted a mother black bear and two cubs on a field survey, sprung bull moose while collecting water quality samples, night snorkeled a restored floodplain to find bull trout, and more. I completed my graduate research on hydrologic impacts of forest management on Lassen National Forest (Hydrologic Impacts of Forest Thinning: A Plot Scale Analysis, Serpa 2020, University of Nevada Reno). I'm an avid outdoor enthusiast, adventuring by foot, by bike, by packraft, and by rope, who takes every opportunity to share my love for our public lands with my two children who are 1 and 5 years old, especially in the Prescott, Kaibab, and Coconino National Forests near our home in Prescott Valley AZ. I have an intimate knowledge and connection to what lies beyond the end of the roads in our nation's Roadless Areas. In response to the U.S. Department of Agriculture's announcement that it is proposing a complete rollback of the 2001 Roadless Rule, I ask you to resist making this change. This is a move that, if finalized, would be the largest loss of protections for rivers on federal lands in U.S. history. Since 2001, the Roadless Rule has protected millions of acres of national forest lands that form the headwaters of some of the nation's most critical drinking water sources. Roadless areas safeguard more than 80,000 miles of rivers and streams, protecting fish and wildlife habitat and helping ensure clean drinking water for more than 25 million Americans, including residents of Denver, Atlanta, and Bozeman. This repeal threatens a conservation legacy that benefits all Americans. I urge you to conserve our nation's roadless forests and keep the Roadless Area Conservation Rule in place. I urge you on behalf of me, but more over on behalf of my 1 and 5 year old daughters, so that they may have the opportunity to experience what lies beyond the “end of the road” throughout their lives, and their children's lives. Even if they choose not to go and see these places, they will be among the millions of Americans who rely on the water and other and environmental services these Roadless Areas provide. Please DO NOT rescind the Roadless Area Conservation Rule. We all need these places to remain protected, so take action on my behalf, and on behalf of my daughters to uphold their protection. Please reconsider this action, and keep the Roadless Rule as it is: a significant protection for rivers, clean water, and wildlife across the country. Sincerely, Benjamin Serpa 7658 N Winding Trl Prescott Valley, AZ 86315 bserpa213@gmail.com Sincerely, Benjamin Serpa

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