Comment Analysis · Docket FS-2025-0001

FS-2025-0001-406257

Supports rescissionA2 moderateSubstance 8/24Owed an answerPosted September 15, 2026 On Regulations.gov

In short: The comment establishes that the agency's summary of the 2001 Roadless Rule's purpose is factually incomplete by omitting its temporary nature and Congressional role, and requests that the Forest Service submit individual forest proposals to Congress for wilderness designation while halting active land management only during that review period.

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

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

Owed an answer on Analytical gap, Alternative.

Standard dismissals it defeats

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.

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.
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

Governance Policy Process
- “Congress never made a reasonable effort to perform this review”
- “return to the original purpose of the roadless rule”
- “get proposals submitted to Congress, individual forest by forest”
- “Congress dropped the ball”
Forest Management Wildfire
- “single greatest obstruction to active land management”
- “so much public land needs so much careful attention”
- “halt temporarily any active land management nationwide”
- “forest pest management responsibility”
Legal Regulatory Framework
- “frequently conflicting judicial decisions”
- “transmogrified the roadless rule's intent and purpose”
- “permanent halt to active land management”
- “widespread social movement to preclude permanently any active land management”

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapLegal

I am a retired USDA Forest Service entomologist who served from 1991 to 2019 in a group that is currently known as Forest Health Protection. Under the Cooperator Forestry Assistance act as amended, this group has forest pest management responsibility on all federal forested lands including those held in trust for tribes and tribal members. I therefore speak from experience having worked on national forests in Montana, Wyoming, South Dakota, Nebraska, Colorado, and Oregon. During my career, the roadless rule was created specifically that Congress, the sole designator of wilderness, would review the existing inventoried roadless areas for potential candidate consideration as additional wilderness areas. The purpose of the roadless rule was to halt temporarily any active land management nationwide that might interfere with Congressional consideration by potentially disqualifying inventoried roadless areas through active land management or other disturbances. The current roadless rule recision proposal summarizes the initial purpose of the roadless rule as follows,"In 2001, USDA and the Forest Service asserted that a national prohibition was the best means to reduce conflict and potential for incremental impacts to the ecological and social values of these areas." This is a serious error, as it is essentially incomplete. The temporary nature of this rule, as well as the essential purpose and need that Congress was to fulfill by review and decision regarding candidate wilderness areas are missing. In my experience, Congress never made a reasonable effort to perform this review and remained mute while misinformation and seemingly endless, frequently conflicting judicial decisions transmogrified the roadless rule's intent and purpose to become a permanent halt to active land management in all inventory roadless areas. In addition, candidate roadless areas, proposed though not officially designated by inventory, somehow became included in what I would describe as a widespread social movement to preclude permanently any active land management in all of these areas. Where we find ourselves today is ever so far from how the roadless rule began and what was intended. During the time that I worked on national forest lands, the roadless rule "evolved" into the single greatest obstruction to active land management. It has failed and fouled miserably, now a total mess. Both society and apparently the authors of the recession proposal do not understand the purpose, intent, and need of the original roadless rule. Congress dropped the ball, which metaphorically has crushed we who worked diligently to care for the land and the people. Because of its failure and what it has become through evolving public opinion and judicial inconsistency, I write in favor of the rescission of the roadless rule as stated in the proposal. I am, however, a staunch advocate for the creation of additional wilderness through Congressional designation and urge the USDA Forest Service to return to the original purpose of the roadless rule and get proposals submitted to Congress, individual forest by forest. Such a proposal should halt active land management until a decision is made by Congress. Meanwhile, we cannot just sit on our hands waiting to find out what might be preserved as wilderness while so much public land needs so much careful attention. Thank you for your consideration of my input. Yours truly, Willis C. Schaupp, Jr., PhD USDA Forest Service (retired)