Comment Analysis · Docket FS-2025-0001

FS-2025-0001-428101

Opposes rescissionA0 noneSubstance 6/24Posted 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

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
    • “lack of concern for the inherent biodiversity of wild forests”
    • “Roads fragment habitats, which impacts wildlife”
    • “Habitat loss is a major cause of biodiversity loss”
    • “No shrub understory, no wildflowers, no orchids, no visible fungi, and no birds or animals”
  • Climate Carbon Storage
    • “Forests are major carbon sinks”
    • “Deforestation is a major contributor to climate change”
    • “stabilize and cool the planet”
    • “sequester carbon dioxide from the atmosphere”
  • Water Quality Quantity
    • “Forests play a major role in the water cycle”
    • “help maintain water quality by filtering out toxic pollution”
    • “Forests slow down the movement of water, preventing landslides & floods”
    • “poisoned by toxic herbicides”
  • Recreation Tourism Public Use
    • “hiked all over the PNW, including roadless areas”
    • “Recreational tourism dollars sustain rural communities”
    • “enjoyed many from a distance”
    • “hike the trail on Lookout Mountain in Oregon”

What it names

National Forests
Gifford Pinchot National Forest
Roadless areas
Badger CreekLookout Mountain
Works cited
Johnston et al. 2023

The comment

I am writing to oppose the proposed rescission of the Roadless Rule. I am a senior who has hiked all over the PNW, including roadless areas, and a mother who raised a son who hikes and backpacks in roadless areas. Most importantly, I am a public lands owner, a taxpayer who believes it is my responsibility to protect public lands. I live in the PNW, surrounded by thousands of acres of roadless areas. I have hiked into some, but enjoyed many from a distance. Each summer, I hike the trail on Lookout Mountain in Oregon and eat lunch while looking over the Badger Creek roadless area: forested mountain foothills dotted with occasional lakes. I regularly hike trails in the Gifford Pinchot National Forest that offer views of roadless areas. I live in a rural community, and many of the parcels around my five acres are privately owned by forest products companies and have been clear-cut. I have witnessed the complete destruction of forests multiple times. After timber corporations remove the dead trees from the razed forest, they spray the entire parcel with a toxic herbicide before planting Douglas Fir seedlings (the preferred species for commercial harvesting in the PNW) in rows, creating a tree plantation where a forest once stood. Twelve years later, those trees are growing, along with a few native species (elderberry, Oregon grape, gooseberry, yarrow). No shrub understory, no wildflowers, no orchids, no visible fungi, and no birds or animals. Aside from the trees, it is a dead zone; a tree plantation. The timber corporation will return in four decades to cut the trees, poison the land, and replant the plantation. Every day I walk a road bordered by clear-cuts, and the lack of other species weighs on my soul. Millions of birds have already disappeared because of habitat loss; insects, butterflies, and bees lose habitat and are poisoned by toxic herbicides. I lost two beehives because of the herbicides used on nearby clear-cuts. Forests are critical to our planet's health and the survival of its many species. I have created a list of why roadless areas matter. 1) Trees serve humanity every day: they regulate the atmosphere and oceans, hold ancient medicines for healing, inspire awe and wonder, teach us new things about life and living, model collaboration and connection, and stabilize and cool the planet. 2) Forests are major carbon sinks: they sequester carbon dioxide from the atmosphere, absorbing greenhouse gas emissions from the burning of fossil fuels. Deforestation is a major contributor to climate change and increases the risk and intensity of natural disasters. 3) When sustainably managed, forests provide food, medicine, shelter, jobs, and fuel for billions of people. Most importantly, we live because they provide oxygen. 4) Forests help build and nourish soil and prevent erosion. 5) Forests slow down the movement of water, preventing landslides & floods. 6) Forests play a major role in the water cycle and help maintain water quality by filtering out toxic pollution. 7) Forests are living systems that provide habitats for 80% of land-based species. Roads fragment habitats, which impacts wildlife. 8) Habitat loss is a major cause of biodiversity loss. 9) Recreational tourism dollars sustain rural communities; extractive dollars are a boom-and-bust economy. Once the trees are cut, the corporations move on. 10) Road building will increase wildfire risk (even the feds acknowledge this) and invasive species. National forests already have a huge maintenance backlog for Forest Service roads. The most important issue is the lack of concern for the inherent biodiversity of wild forests. Our God-given purpose is to steward life on this planet, ensuring that animal and plant species have a habitat to live in. Public lands belong to the public, not private corporations that rape the land and move on to the next parcel, caring little about ecosystems and rural communities. Don't sell out our forests and grasslands to international corporations that couldn't care less about life. Their entire business model is based on destruction and death.

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