Comment Analysis · Docket FS-2025-0001

FS-2025-0001-438509

Opposes rescissionA0 noneSubstance 5/24Posted September 17, 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 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

Wildlife Habitat
- “extraordinary birds in the United States depend on large, intact forests”
- “Mature and old-growth forests provide structural complexity, nesting sites”
- “Protecting bird habitat therefore protects far more than birds”
- “remnants of New England's increasingly rare old-growth ecosystems”
Environmental Protection Biodiversity
- “living communities whose complexity has taken decades or centuries to develop”
- “These forests protect wildlife habitat, watersheds, biodiversity”
- “We should not knowingly trade irreplaceable habitat and clean water”
- “Healthy forests, clean water, biodiversity, and functioning ecosystems”
Water Quality Quantity
- “These forests protect wildlife habitat, watersheds, biodiversity”
- “trade irreplaceable habitat and clean water for short-term extractive interests”
- “Healthy forests, clean water, biodiversity”
Recreation Tourism Public Use
- “As a birder, I experience forests not simply as stands of trees”
- “future generations deserve the opportunity to encounter wild places”
- “opportunities for people to experience genuinely wild landscapes”

The comment

I strongly urge the Forest Service to withdraw its proposal to rescind the 2001 Roadless Area Conservation Rule. As a birder, I experience forests not simply as stands of trees, but as living communities whose complexity has taken decades or centuries to develop. Some of the most extraordinary birds in the United States depend on large, intact forests for breeding, feeding, migration, and shelter. Mature and old-growth forests provide structural complexity, nesting sites, food webs, and connected habitat that cannot simply be replaced by planting new trees after logging. Once an old forest is lost, we cannot manufacture another one on a timeline meaningful to the birds and other wildlife that depend upon it. Birds are also not decorative additions to these ecosystems. They are part of how forests function: dispersing seeds, controlling insect populations, moving nutrients through ecosystems, and serving as sensitive indicators of environmental health. Protecting bird habitat therefore protects far more than birds. This is especially personal to me because of my connection to the forests surrounding Maine's Caribou-Speckled Mountain Wilderness and nearby Roadless Areas. Knowing that places like these still contain relatively intact forests, including remnants of New England's increasingly rare old-growth ecosystems, is profoundly meaningful to me as a birder and as someone who believes future generations deserve the opportunity to encounter wild places that have not been fragmented by roads and industrial development. The Roadless Rule has provided nationwide conservation protections for more than 25 years. Rescinding it would remove restrictions on road construction, reconstruction, and timber harvest across nearly 45 million acres of National Forest System lands. These forests protect wildlife habitat, watersheds, biodiversity, and opportunities for people to experience genuinely wild landscapes. We already know how difficult it is to restore an ecosystem after its complexity has been lost. We should not knowingly trade irreplaceable habitat and clean water for short-term extractive interests and then expect future generations to repair the damage. Environmental stewardship should transcend politics. Healthy forests, clean water, biodiversity, and functioning ecosystems are matters of public interest and public health. Please preserve the protections Americans have relied upon for a quarter century and withdraw the proposal to rescind the Roadless Rule. Sincerely, Jess Singleton 612 W 147th St Apt 4 New York, NY 10031-4311 jess.singleton@gmail.com