Comment Analysis · Docket FS-2025-0001

FS-2025-0001-434697

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

In short: The comment establishes that the 2001 Roadless Rule is complex to rescind and documents a request to delegate authority for temporary roads to the Forest Supervisor level, require local community involvement in access decisions, and commit to specific road maintenance and closure budgets for water quality protection.

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
- “strongly support timber management, fire & fuels management and forest health management”
- “Do Not send the US Forest Service back to the era where no management was accomplished”
- “provide the necessary funding to carry out its mission”
Water Quality Quantity
- “Roads in these sensitive areas caused substantial impacts to water quality”
- “commitment to road maintenance and road closure budgets that will provide for water quality protection”
- “sensitive soils such as highly erosive granitic soils, wetlands, meadows and stream course crossings”
Governance Policy Process
- “Local community involvement in decision making to adjust roadless area access”
- “Authority for approving temporary roads into road less areas must be delegated to the Forest Supervisor level”
- “staff the US Forest Service adequately”

The comment

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

The 2001 Roadless Rule is more complex than simply rescinding it. The National Forests were established to provide public benefits and access. I worked for the US Forest Service in the Sierra Nevada on multiple forests in California for 33 years between 1979 -2012 in a range of positions including timber management, special uses, recreation and forest health protection doing implementation, environmental planning as a line officer and program manager. I strongly support timber management, fire & fuels management and forest health management. While I believe the 2001 Roadless rule could use some adjustments over the years prior to the roadless rule I saw sensitive soils such as highly erosive granitic soils, wetlands, meadows and stream course crossings highly impacted by indiscriminate vehicle and off-road vehicle use, and mining activity. Roads in these sensitive areas caused substantial impacts to water quality and sensitive habitats. Road maintenance on national forest lands dramatically decreased after timber management was severely curbed by spotted owl management and the public who was against seeing short term impacts from logging. Given that the federal government is 40 trillion dollars in debt, the Iran war is up-to about 38 billion dollars, and the arbitrary firing and forced retirement of much of the skilled US Forest Service workforce I am skeptical that this administration is capable of following through to actually provide adequate road maintenance and a program to close temporary roads. Local community involvement in decision making to adjust roadless area access with temporary roads must be a criteria in the proposed rule. Authority for approving temporary roads into road less areas must be delegated to the Forest Supervisor level. And there needs to be a commitment to road maintenance and road closure budgets that will provide for water quality protection. Do Not send the US Forest Service back to the era where no management was accomplished due to public outrage and constant litigation. Be thoughtful, staff the US Forest Service adequately and provide the necessary funding to carry out its mission.