Comment Analysis · Docket FS-2025-0001

FS-2025-0001-355818

Opposes rescissionA0 noneSubstance 6/24Posted 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

  • Environmental Protection Biodiversity
    • “maintaining old growth forest”
    • “complex and irreplaceable biodiversity”
    • “conservation of plants, animals, air and water quality”
  • Water Quality Quantity
    • “protecting the sources of clean drinking water”
    • “water quality”
  • Recreation Tourism Public Use
    • “hiker, river rafter, and camping enthusiast”
    • “pristine wilderness”
    • “wilderness outfitters and guides”
  • Economic Impact Fiscal
    • “economic benefit from rescinding the roadless rule would be outweighed by the many costs”
    • “projected timber revenues cannot cover the massive costs”
    • “lost revenue due to changes in landscape”

What it names

National Forests
Kootenai National ForestOlympic National Forest

The comment

Dear Forest Service,
 I write to urge you to maintain the the 2001 Roadless Area Conservation Rule (2001 Roadless Rule), as it currently exists, keeping the broad prohibitions on road construction, road reconstruction, and timber harvesting that are currently in place. Roadless wilderness is crucial for protecting wildlife, protecting the sources of clean drinking water, and maintaining old growth forest that captures carbon in ways that younger woods cannot and contains complex and irreplaceable biodiversity. Once a road is built in one of these areas, the chances of the area being disturbed in further and detrimental ways is high. But even one road in the midst of a wilderness area does irreparable harm. As a hiker, river rafter, and camping enthusiast, I am especially concerned with maintaining the pristine wilderness with United States is lucky to have. I’m particularly concerned about and attached to the Shawnee Forest in the southern part of my own home state of Illinois, and also the Kootenai National forest in Idaho and the Olympic National Forest in Washington State, where my family and I have spent many vacations and had life changing wilderness experiences. Any supposed economic benefit from rescinding the roadless rule would be outweighed by the many costs. The maintenance needed on the 368,000 miles of roads in America’s national forests was one impetus for the Roadless Rule in 2001. Roads in these wilderness areas are extremely expensive to maintain, and the economic analysis that the recession proposal is based on is flawed because projected timber revenues cannot cover the massive costs of building and maintaining new roads in remote forests. There would also be significant economic impacts to businesses that connect people with wilderness experiences. Wilderness outfitters and guides operating under special use permits would see a great deal of lost revenue due to changes in landscape, recreation quality, and wildlife habitats. Most important are the non-commodity values that roadless areas provide. These values pertain to the ecological, recreational, passive use, and aesthetic benefits of roadless areas and include things like the conservation of plants, animals, air and water quality, a desire to experience solitude and personal renewal in wild areas, a sense-of-place attachment to a specific area, the desire to leave a legacy of natural areas for future generations to experience and benefit from. Both the economic and non-commodity value of well-functioning ecosystems and biodiversity are tremendous and difficult to accurately measure.. Please maintain the roadless rule and protect our nations old growth forests and back country wilderness. Future generations as well as Americans of today are counting on you. Sincerely, Elizabeth Majerus Urbana, Illinois

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