Comment Analysis · Docket FS-2025-0001

FS-2025-0001-433961

Supports rescissionA0 noneSubstance 8/24Posted September 16, 2026 On Regulations.gov

In short: The comment establishes the commenter's standing as a Good Neighbor Authority Forester in Clearwater County, Idaho, and documents specific operational constraints on the Nez Perce-Clearwater National Forest, including the inability to treat burned roadless areas in the Dixie-Comstock Community Protection Project and the resulting economic impacts on the working land base.

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
    • “forest health and fuels treatment projects”
    • “burned roadless areas adjacent to communities could not be treated”
    • “implementing forest health”
  • Economic Impact Fiscal
    • “severely diminished working land base”
    • “cascading economic and workforce impacts”
    • “forest-dependent communities”
  • Governance Policy Process
    • “de facto prohibition that results from litigation risk”
    • “rebalance the multiple use mandate”
    • “shifted persistently toward preservation”

What it names

National Forests
Nez Perce-Clearwater National Forest

Attachments

1 file. Counts as 1 — Counts as one: The attachments enclose no one else's submissions; the comment counts as one.

  • Own letter

The comment

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

I am writing in support of the proposed rescission of the 2001 Roadless Area Conservation Rule. I am a forester in Clearwater County, Idaho, working with the Idaho Department of Lands under the Good Neighbor Authority program on the Nez Perce-Clearwater National Forest, with direct involvement in implementing forest health and fuels treatment projects on National Forest System lands. My comments address four substantive issues: (1) the de facto prohibition that results from litigation risk regardless of Idaho's state-petitioned rule; (2) the direct consequences I observed during implementation of the Dixie-Comstock Community Protection Project, where burned roadless areas adjacent to communities could not be treated; (3) the severely diminished working land base on the Nez Perce-Clearwater and its cascading economic and workforce impacts; and (4) the need to rebalance the multiple use mandate that has shifted persistently toward preservation at the expense of forest-dependent communities. My full comment is attached as a PDF document. Docket: FS-2025-0001 | RIN 0596-AD66 Jarel Bruce Good Neighbor Authority Forester Idaho Department of Lands — Nez Perce-Clearwater National Forest

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