Comment Analysis · Docket FS-2025-0001

FS-2025-0001-447200

Opposes rescissionA0 noneSubstance 3/24Posted September 18, 2026 On Regulations.gov

Campaign — One letter sent by 10 or more people, copied or lightly reworded. This comment stands for 178 submissions in its group. See the letter, its submissions and topics.

Scored as the letter — The shared letter of a family, scored once for everyone who sent it.

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

  • Environmental Protection Biodiversity
    • “expose mature and old-growth forests to unnecessary commercial harvesting”
    • “enforceable protections for existing old-growth trees and ecologically significant mature forests”
    • “irreplaceable old trees”
    • “mature and old-growth forests we cannot replace within our lifetimes”
  • Forest Management Wildfire
    • “legitimate wildfire prevention”
    • “public safety and ecological restoration”
    • “responsible forest-management tools”

The comment

I oppose rescinding the Roadless Rule without clear safeguards as this could expose mature and old-growth forests to unnecessary commercial harvesting and permanent road construction. Before changing the rule, I respectfully ask the Forest Service to establish enforceable protections for existing old-growth trees and ecologically significant mature forests. Any exceptions should allow legitimate wildfire prevention, public safety and ecological restoration while preventing those exceptions from becoming a pathway for unnecessary commercial removal of irreplaceable old trees. These forests took centuries to develop and cannot simply be replaced by planting new trees. Please preserve responsible forest-management tools while adding clear protections for the mature and old-growth forests we cannot replace within our lifetimes.

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