Comment Analysis · Docket FS-2025-0001

FS-2025-0001-400953

Opposes rescissionA0 noneSubstance 5/24Posted September 14, 2026 On Regulations.gov

Small family — One letter sent by 3 to 9 people, copied or lightly reworded. One of 3 submissions in its group; the sender added words of their own. See the letter, its submissions and topics.

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

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
    • “Preserving Big Game Habitat”
    • “Road construction fragments critical wildlife migration corridors”
    • “pushes big game like elk and deer out of their native ranges”
    • “Intact, roadless acres keep wildlife populations healthy”
  • Water Quality Quantity
    • “Safeguarding Coldwater Fisheries”
    • “Dirt roads built for extraction cause heavy soil erosion”
    • “washing mud and debris into mountain streams”
    • “protects vital headwaters, keeping trout habitats cold, clean, and productive”
  • Recreation Tourism Public Use
    • “Defending the Backcountry Experience”
    • “Millions of hikers, backpackers, and anglers access national forests specifically to seek solitude”
    • “Allowing new roads introduces motorized vehicle noise and heavy crowds”
    • “permanently ruining the primitive backcountry environment”
  • Economic Impact Fiscal
    • “Fiscal Responsibility for Taxpayers”
    • “U.S. Forest Service already faces a massive $10.8 billion deferred maintenance backlog”
    • “fiscally irresponsible to spend taxpayer dollars on new road construction”
    • “agency cannot afford to maintain the roads it already manages”

The comment

To Whom It May Concern, I am writing as an avid outdoorsman, hunter, and angler to register my strong opposition to the U.S. Department of Agriculture’s proposal to rescind the 2001 Roadless Area Conservation Rule. Stripping protections from tens of millions of acres of wild national forest land directly threatens our nation's finest backcountry habitats and the multi-billion-dollar outdoor recreation economy. Our public lands are the backbone of our country's sporting heritage. My opposition to the rollback is rooted in five critical areas: Preserving Big Game Habitat: Road construction fragments critical wildlife migration corridors and pushes big game like elk and deer out of their native ranges. Intact, roadless acres keep wildlife populations healthy and preserve the traditional spirit of the fair chase. Safeguarding Coldwater Fisheries: Dirt roads built for extraction cause heavy soil erosion, washing mud and debris into mountain streams. Leaving these areas roadless protects vital headwaters, keeping trout habitats cold, clean, and productive. Defending the Backcountry Experience: Millions of hikers, backpackers, and anglers access national forests specifically to seek solitude. Allowing new roads introduces motorized vehicle noise and heavy crowds, permanently ruining the primitive backcountry environment. Fiscal Responsibility for Taxpayers: The U.S. Forest Service already faces a massive $10.8 billion deferred maintenance backlog on its existing road network. It is fiscally irresponsible to spend taxpayer dollars on new road construction when the agency cannot afford to maintain the roads it already manages. Mitigating Wildfire Risk: Proponents argue that roads allow better fire management, but forest science shows that the vast majority of human-caused wildfires ignite near roads. Paving new pathways into remote terrain actually increases the risk of accidental ignitions. Decades of public feedback show that the vast majority of Americans want these backcountry spaces left in public hands, undeveloped and unfragmented. I urge the USDA and the Forest Service to abandon this rescission and maintain the historic protections of the Roadless Rule for future generations of outdoor enthusiasts. Sincerely, Bobby Hatfield Litchfield Park, AZ, 85340

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