Comment Analysis · Docket FS-2025-0001

FS-2025-0001-418448

Opposes rescissionA1 strongSubstance 4/24Owed an answerPosted September 16, 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

A1 strong: Must be answered — it names the law.

Owed an answer on Legal.

Standard dismissals it defeats

  • 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.
  • 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.
  • 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.

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.
  • 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.

Topics

  • Environmental Protection Biodiversity
    • “Roads are the single greatest driver of habitat fragmentation”
    • “protects 58.5 million acres of exactly that kind of place”
    • “prevents the kind of industrial logging and road-building”
  • Water Quality Quantity
    • “These roadless forests are the headwaters for municipal water supplies”
    • “serving more than 60 million people across 3,400 communities”
  • Recreation Tourism Public Use
    • “The outdoor recreation economy that depends on them is worth billions of dollars”
    • “wild, quiet, and worth the trouble of getting to”
    • “hiked a trail in Sequoia National Park where the only sound was water over granite”
  • Forest Management Wildfire
    • “Wildfires are four times more likely to start near a road”
    • “over 90% of wildfires occur within half a mile of one”
    • “The rule already includes exceptions for fire management”

What it names

Law cited
36 CFR Part 294

The comment

I am commenting on the proposed rescission of 36 CFR Part 294, Subpart B Last summer I hiked a trail in Sequoia National Park where the only sound was water over granite and wind through ancient redwood trees. No roads. No trucks. No chainsaws. Just a forest that has been growing, undisturbed, for centuries. That kind of place is rare now, and it is beautiful in a way that no photograph or description can fully capture. Please keep the Roadless Rule. The Roadless Area Conservation Rule protects 58.5 million acres of exactly that kind of place. I'm asking you to keep it. Beyond the beauty, the practical case is strong. Roads are the single greatest driver of habitat fragmentation in the West. Wildfires are four times more likely to start near a road, and over 90% of wildfires occur within half a mile of one. These roadless forests are the headwaters for municipal water supplies serving more than 60 million people across 3,400 communities. The outdoor recreation economy that depends on them is worth billions of dollars a year to rural towns that would feel the loss first. The rule already includes exceptions for fire management, insect control, and other stewardship needs. What it prevents is the kind of industrial logging and road-building that trades long-term, irreplaceable value for short-term gain. I don't ask for a new rule. I ask that you leave the one that works in place. Let these forests keep being what they are — wild, quiet, and worth the trouble of getting to. Thank you for considering this. Qwin White 20008 Sherman Way Apt A Winnetka, Ca, 91306. qwin.white@gmail.com

Keep learning. Keep speaking up.The Roadless Rule depends on public engagement. Share what you've learned.

© 2026 roadless.org - Defending America's Last Wild Forests

Privacy Policy|Questions or concerns? noroads@roadless.org|Follow us: @defendroadless