Comment Analysis · Docket FS-2025-0001

FS-2025-0001-441944

Opposes rescissionA2 moderateSubstance 5/24Owed an answerPosted 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

A2 moderate: Hard to dismiss — it shows cause and effect.

Owed an answer on Alternative.

Standard dismissals it defeats

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.

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.
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
- “wildfire risk, particularly in the wildland-urban interface”
- “targeted fuel-treatment and access authority”
- “more roads can increase human-caused ignition risk”
Recreation Tourism Public Use
- “estimating $6.1M/year in lost recreation value”
Legal Regulatory Framework
- “retain the national rule”
- “expand its existing exception process”
- “blanket rescission”

The comment

I am writing to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. The rule's own justification is centered on wildfire risk, particularly in the wildland-urban interface. If that is the real concern, the response should be a targeted fuel-treatment and access authority for that specific problem instead of a blanket rescission. The Department's own analysis undercuts the broader rationale: only ~16% of forested roadless acreage is rated operable for timber harvest, high-end harvest projections are called "unlikely," and the Forest Service already has a $6.9 billion road maintenance backlog. The proposal also concedes that more roads can increase human-caused ignition risk, which directly undermines the wildfire-safety rationale, while estimating $6.1M/year in lost recreation value. A narrower path exists: retain the national rule and expand its existing exception process for fuel treatment and fire-related access in the wildland-urban interface, rather than eliminating protections nationwide.