Comment Analysis · Docket FS-2025-0001

FS-2025-0001-412992

Supports rescissionA0 noneSubstance 6/24Posted September 15, 2026 On Regulations.gov

In short: The comment documents the commenter's support for rescinding the 2001 Roadless Area Conservation Rule, arguing that centralized management has been ineffective and costly, and requesting that road management be decentralized to local National Forest Supervisors with specific requirements for resource allocation, plan revision timelines, and road maintenance standards.

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

Forest Management Wildfire
- “loss of millions of acres of overgrown forests to wildfire, disease, and drought”
- “forest thinning for fire mitigation”
- “safe ingress and egress during wildfire events”
- “having more trees does not translate into having a healthy forest”
Governance Policy Process
- “decentralize road management and place responsibility... with individual National Forest Supervisors”
- “local supervisors are far better positioned to understand the environmental conditions”
- “Each National Forest's Land Management Plan should address road system needs based on local conditions”
- “taking more than seven years to revise a Land Management Plan is unacceptable”
Economic Impact Fiscal
- “losses represent billions of dollars in natural resources”
- “timber that could have been used to build affordable housing”
- “prove ineffective and costly”
- “Individual National Forests must be adequately resourced—with both funding and personnel”

What it names

National Forests: Lincoln National Forest

The comment

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

As a Lincoln National Forest Grazing allotment owner, I support the rescission of the 2001 Roadless Area Conservation Rule and offers the following comments: •Since 2001, I have witnessed the Roadless Rule—through centralized management and an extensive history of litigation—prove ineffective and costly. The rule never produced the expected results. •The results from widespread mismanagement as resulted in the loss of millions of acres of overgrown forests to wildfire, disease, and drought. •These losses represent billions of dollars in natural resources, including timber that could have been used to build affordable housing to replace homes lost to wildfires and to address the severe housing shortages frequently highlighted in media coverage of homelessness in major urban areas. I support rescinding the 2001 Roadless Rule because it will decentralize road management and place responsibility for creating, decommissioning, and maintaining roads with individual National Forest Supervisors. •Each National Forest is unique, and local supervisors are far better positioned to understand the environmental conditions and management needs of their respective forests than staff located in Washington, D.C., thousands of miles removed from on the ground realities. •Local decision making regarding road creation, maintenance, or decommissioning must consider multi use objectives such as recreation, grazing, forest thinning for fire mitigation, and overall forest health. I want to point out that having more trees does not translate into having a healthy forest, especially during droughts in the southwest. •Roads that were decommissioned under the Rule rarely received the funding necessary to address erosion issues either before or after decommissioning. Forest Supervisors should work directly with local Soil and Water Conservation Districts to resolve these problems. •Each National Forest’s Land Management Plan should address road system needs based on local conditions and priorities. •Roads identified as Potential Operational Delineation (POD) boundaries must be thinned and upgraded to standards that ensure safe ingress and egress during wildfire events. •Individual National Forests must be adequately resourced—with both funding and personnel—to maintain existing roads and prevent the creation of illegal user built roads and illegal dumping on Forest Service lands. •Individual National Forests should provide clear, detailed information in their Land Management Plans describing how they will manage the road system. Additionally, taking more than seven years to revise a Land Management Plan is unacceptable; for example, the revision of the 1986 Lincoln National Forest Plan, ongoing since 2019, has taken far too long with no clear end in sight.