Comment Analysis · Docket FS-2025-0001

FS-2025-0001-434821

Opposes rescissionA1 strongSubstance 9/24Owed an answerPosted September 16, 2026 On Regulations.gov

In short: The comment documents the commenter's opposition to the rescission of the 2001 Roadless Area Conservation Rule, specifically arguing that the 30-day comment period is insufficient compared to the original rulemaking process and requesting the withdrawal of the proposed rescission of 36 CFR part 294, Subpart B.

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.
Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
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.

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.
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.

Topics

Wildlife Habitat
- “security cover elk, mule deer, and bear actually use”
- “fragment habitat”
- “high overlap between roadless acres and big-game habitat”
Water Quality Quantity
- “hold intact watersheds”
- “cold-water fisheries”
- “put sediment in streams”
Governance Policy Process
- “no comparable public process”
- “A 30-day period... is not a substitute for the process that created the rule”
- “return decisions to the forest plan... Plans change”
Forest Management Wildfire
- “Wildfires are more likely to start where roads already exist”
- “fund and prioritize work in the wildland-urban interface”
- “treat unroaded backcountry as the default treatment unit”

What it names

Law cited: 36 CFR part 294

The comment

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

Director, Ecosystem Management Coordination 201 14th Street SW, Mailstop 1108 Washington, DC 20250-1124 Special Areas; Roadless Area Conservation Proposed Rescission of the 2001 Roadless Rule. Subject: Oppose rescission of the 2001 Roadless Area Conservation Rule (RIN 0596-AD66 / Docket FS-2025-0001) To the U.S. Department of Agriculture and U.S. Forest Service: I am writing as a private citizen and outdoorsman who hunts, fishes, and spends time on National Forest lands. I live in the Denver metro area of Colorado. I oppose the proposed rule to rescind the 2001 Roadless Area Conservation Rule in its entirety. I understand the stated purpose: reduce regulatory burden, return decisions to local forest plans, and make it easier to treat fuels and lower wildfire risk. Those are serious goals. They do not require tearing down the national floor that has kept inventoried roadless areas from becoming a default road-and-harvest landscape. What these lands actually provide Inventoried roadless areas are not leftover scraps. They are some of the last large, unroaded blocks on the National Forest System. They hold intact watersheds, cold-water fisheries, and the kind of security cover elk, mule deer, and bear actually use. Analyses used by hunters and anglers show very high overlap between roadless acres and big-game habitat. That is not an abstraction to people who walk those drainages. Roads change the country. They fragment habitat, put sediment in streams, spread weeds, and make it easier for people - and ignition sources - to get farther into the timber. Wildfires are more likely to start where roads already exist than in roadless tracts. Opening more of these acres to construction does not automatically produce healthier forests. It produces more linear disturbance and a larger maintenance bill the Forest Service already cannot keep up with. Taxpayers have carried an enormous road-maintenance backlog for decades. Building more miles into country that has stayed roadless for a reason is not fiscal discipline. The rule is not a total lockout The 2001 rule already allows limited exceptions, including certain hazardous-fuels work, stewardship, and other management. If the problem is that those exceptions are too narrow or too slow, the honest fix is to amend the exceptions and fund the work - not delete the prohibition and hope every forest plan holds the line. Rescission does not require cutting or roadbuilding, but it removes the national constraint. Once that constraint is gone, pressure for timber, minerals, and access will fall on individual supervisors with fewer tools to say no. Colorado context, and why a national rule still matters Colorado has its own Roadless Rule. That state rule is not on the chopping block in this proposal, and I am glad of it. That does not make the national rescission harmless. I use National Forests beyond Colorado. Fish, wildlife, and water do not stop at state lines. A national repeal on the remaining 45 million acres sets the template for how local flexibility will be used everywhere the 2001 rule still applies, including Alaska’s Tongass and forests I travel to for fishing and backcountry time. A floor that took years of hearings and more than a million comments to build should not be removed in a short comment window with no comparable public process. Last year’s scoping already produced hundreds of thousands of comments, the large majority opposed to repeal. That record should count for something. A 30-day period, even extended to October 6, is not a substitute for the process that created the rule. What I am asking you to do 1. Withdraw the proposed rescission of 36 CFR part 294, Subpart B. 2. Keep inventoried roadless areas under a national prohibition on new road construction and most timber harvest, with tightly written exceptions for genuine fuels reduction, public safety, and stewardship that can be done without a permanent road system. 3. If fuels treatment is the driving need, fund and prioritize work in the wildland-urban interface and already-roaded acres first - the places where homes, infrastructure, and existing access already concentrate risk - rather than treating unroaded backcountry as the default treatment unit. 4. Do not treat “return decisions to the forest plan” as equivalent to protection. Plans change. A national rule is the only durable check most of these acres have. I am not opposed to active management. I am opposed to confusing management with a permanent road network in the last unroaded national forest country we still have. Once a road is in, the place is not roadless anymore. That change does not reverse on a planning cycle. Please retain the 2001 Roadless Area Conservation Rule. Respectfully, Leo Sands Wheat Ridge, CO 80033 Leo.Sands42@gmail.com