Comment Analysis · Docket FS-2025-0001

FS-2025-0001-433736

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

  • Water Quality Quantity
    • “supply headwater streams that feed drinking water”
    • “degrade water quality”
    • “drinking water for millions of Americans”
  • Wildlife Habitat
    • “habitat for fish and wildlife”
    • “fragment habitat”
    • “irreplaceable public values”
  • Recreation Tourism Public Use
    • “best remaining opportunities for quiet recreation”
    • “supported by a wide range of stakeholders including hunters, anglers, hikers”
    • “last unroaded, undeveloped National Forest lands”
  • Governance Policy Process
    • “A national floor is needed”
    • “removes the consistent, nationwide baseline”
    • “operate within a national framework”

What it names

Law cited
36 CFR Part 294

The comment

I write to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (36 CFR Part 294, Subpart B). The rule protects roughly 58.5 million acres of the last unroaded, undeveloped National Forest lands, and I believe removing those protections is the wrong approach for the following reasons: 1. The rule is overwhelmingly popular and has broad, bipartisan support. Since 2001, public comments have run heavily in favor of protecting roadless areas, and the rule has been supported by a wide range of stakeholders including hunters, anglers, hikers, and many rural communities. Rescinding it would overturn protections the public has repeatedly asked to keep.2. Roadless areas provide irreplaceable public values. These lands supply headwater streams that feed drinking water for millions of Americans, habitat for fish and wildlife, and some of the best remaining opportunities for quiet recreation. Road construction and timber harvest in these areas would fragment habitat and degrade water quality in ways that are difficult or impossible to reverse. 3. A national floor is needed. Returning decisions entirely to individual forest plans removes the consistent, nationwide baseline that has protected these areas from piecemeal development. Local planning processes are valuable, but they should operate within a national framework that preserves the core values of roadless areas.I urge the Forest Service to withdraw this proposal and instead work within the existing Roadless Rule to address localized concerns such as wildfire risk and forest health. Thank you for your consideration.

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