Comment Analysis · Docket FS-2025-0001

FS-2025-0001-444909

Opposes rescissionA2 moderateSubstance 9/24Owed an answerPosted September 17, 2026 On Regulations.gov

In short: The comment documents that the Draft EIS failed to include Tribal-proposed alternatives and that the current process lacks public meetings, while citing specific Forest Service data showing a 4x higher fire risk near roads to argue against the rule's rescission.

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 Analytical gap, Evidence.

Standard dismissals it defeats

  • 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.

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.
  • 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.
  • 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

  • Water Quality Quantity
    • “conserve fresh water”
    • “94,000 miles of rivers are protected”
    • “put the supply of drinking water for more than sixty million Americans at risk”
  • Wildlife Habitat
    • “Five of the eight species of western native trout rely on roadless areas”
    • “Native Gila Trout use roadless areas for 99% of its habitat”
    • “safe habitats and migration routes for grizzly bears, wolves, elk and mule deer”
  • Tribal Sovereignty
    • “robust input from the public and tribal nations”
    • “The alternatives proposed by Tribal Governments were not included in the DEIS”
    • “significantly alter Tribal access to treaty-reserved resources, sacred sites”
  • Governance Policy Process
    • “developed after a lengthy and thorough process”
    • “Forest Service held 600 public hearings and received 1.6 million comments”
    • “current process includes NO public meetings and an extremely short comment period”

What it names

National Forests
Gifford Pinchot National ForestOkanogan National ForestOlympic National ForestTongass National ForestUmatilla National ForestWenatchee National Forest

The comment

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

I am writing today in support of Alternative 1 – No Action, 2001 Roadless Area Conservation Rule. Keeping the status quo will continue to protect these roadless public lands and conserve fresh water and forests for people and wildlife. Currently, 94,000 miles of rivers are protected by the rule. Rolling back the rule will put the supply of drinking water for more than sixty million Americans at risk. Five of the eight species of western native trout rely on roadless areas for more than half of their habitat. Native Gila Trout use roadless areas for 99% of its habitat. Roadless areas provide safe habitats and migration routes for grizzly bears, wolves, elk and mule deer. The Tongass National Forest has 800-year-old trees and over fifty million fish. This is a critical habitat that sequesters carbon, provides recreational activities, and contains important cultural sites. I live in the state of Washington where several areas are protected by the roadless rule including Olympic National Park, Gifford Pinchot National Forest, Mt. Baker-Snoqualmie National Forest, Okanogan National Forest, Olympic National Forest, Umatilla National Forest, and Wenatchee National Forest. These are pristine areas that provide habitat for a wide range of animals. They also provide recreational opportunities for hiking, fishing, hunting, and to simply enjoy nature. People travel from all over the country and even the world to enjoy these areas. The spending from this tourism provides ongoing jobs in rural areas where employment opportunities are few. The 2001 Roadless rule was developed after a lengthy and thorough process that included robust input from the public and tribal nations. The Forest Service held 600 public hearings and received 1.6 million comments on the rule. The current process includes NO public meetings and an extremely short comment period. The alternatives proposed by Tribal Governments were not included in the DEIS. The DEIS states “Timber Harvest and road construction in inventoried roadless areas could significantly alter Tribal access to treaty-reserved resources, sacred sites, and other culturally significant sites.” Stating that one of the purposes of this rule recission for fire management seems to be a scare tactic. Many fires are started by vehicles and people using roads in forested areas. An analysis of data from the U.S. Forest Service for the period of 1992 to 2024, shows that within 50 meters of a forest road there is a 4x greater chance of a fire starting than in roadless areas. These areas should remain roadless for the protection of these pristine lands to preserve the forest and waterway.

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