Opposes rescissionA0 noneSubstance 5/24Posted 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 eliminatedThe agency says it considered and eliminated the alternative the comment proposes, with a reason. Cannot be defeated from the comment text alone.
Already addressedThe 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 decisionThe agency says the point belongs to a later, site-specific decision. Cannot be defeated from the comment text alone.
Misreads the proposalThe agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
Not requiredThe agency says the analysis the comment asks for is not required. Cannot be defeated from the comment text alone.
Preference notedThe 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 shownThe agency says the comment asserts a harm without showing how the action causes it. Defeated when the comment shows the mechanism.
Outside the scopeThe agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.
Certified not substantiveThe agency certifies the comment raises nothing substantive. Defeated when the comment alleges illegality, which is substantive by the definition the certification runs on.
I was a USFS forester in timber management on the Plumas NF and Ouachita NF culminating my forest management career of 31 years as a Forest Measurements Specialist (Mensurationist) for SE US for Region 8. Timber planning cooperated extensively with engineering for road development and maintenance. Heavy road building in years past put a difficult burden for road maintenance backlogs that affected our ability to plan for future timber removals without significant monetary mitigation needs to protect downstream water values. In fact engineering routinely did not get adequate funding to maintain the roads that existed from previous sales year in to year out. Rescinding the Roadless Rule will simply exacerbate this dilemma likely leading to more downstream erosion if the Rule elimination leads to even more road building on even more extreme rocky steeper terrain.
The areas that were inventoried and designated as part of the Roadless Rule are typically areas with higher recreational values (scenic and hiking), water quality headwater needs, and wildlife values very difficult or rocky terrains than a significantly identified timber resource value or the remote possibility that there are valuable mineral resources to mine.
Sec Rollins has often said she wants to return the decision-making back to the "land managers". These Roadless Areas, contrary to what she has said, were actually identified by the actual land managers (Forest Supervisors and District Rangers), and their specialists such as timber specialists, biologist, hydrologist, soil scientists and planners that actually worked and lived in the villages and towns that they served not some distant planners at a Regional or DC headquarters. We involved our communities in the discussions and the planning just like we did in developing individual timber sales. A majority of our publics were strongly in favor of a light touch or no touch conservation approach for these set asides.
I'd also warn that creating more access to extreme terrains by rescinding the Roadless Rule is likely to make for more man made fire ignitions in places you don't want to send firefighters into. Fires in those terrains are more erratic and endanger their lives. You've already lost 5 lives this year.
In regards to the Tongass NF. I do not know all that went into their effort for their Roadless area but I know 2 significant elements on the Tongass. They have an enormously unique ecosystem in the temperate rainforest throughout the designated Roadless area. You simply cannot find that any where else in the US. It includes enormous water resources for wildlife and downstream users. My friends that used to work there would tell me how they worked very closely with the native tribes to manage the resources for their communities as part of the unique ecosystem. My fear is that Sec Rollins and our current FS Chief have designs on doing industrial clearcut logging. That would be ruinous and moving ahead with such a plan without concurrence from their publics, the tribes in particular, will likely result in endless lawsuits.
Thank you for your time.