Comment Analysis · Docket FS-2025-0001

FS-2025-0001-448511

Opposes rescissionA1 strongSubstance 7/24Owed an answerPosted September 21, 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

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

Environmental Protection Biodiversity
- “protects some of the wildest forests we have left”
- “protect critical wildlife habitat”
- “Revoking the Roadless Rule puts landscapes, wildlife, and communities at risk”
Water Quality Quantity
- “protect critical wildlife habitat and drinking water for millions”
Public Opinion Support
- “wildly popular across the country”
- “over 600,000 people submitting comments... in support of keeping the rule”
- “American people overwhelmingly called for our national forests to be protected”
Legal Regulatory Framework
- “NEPA obligates an agency to study, develop, and describe appropriate alternatives”
- “proposed action does not serve the purpose and need it claims to serve”
- “rulemaking record itself supplies the evidence that contradicts the Department's own rationale”

What it names

Law cited: 42 U.S.C. 4332

The comment

I am deeply concerned about the idea to rescind the roadless rule and what that means for our future. The Department proposes this rescission to reduce regulatory burden, return land management decision-making for inventoried roadless areas to local Forest Service officials, and enable active management response to wildfire risk, insect and disease infestation, and wildland-urban interface (WUI) protection. None of these stated objectives is actually advanced by the proposed action, and the rulemaking record itself supplies the evidence that contradicts the Departmentand#39;s own rationale. Thus, the USFSs proposed action does not serve the purpose and need it claims to serve. NEPA obligates an agency to "study, develop, and describe appropriate alternatives"; to a proposed action, 42 U.S.C. 4332(2)(E), and courts have long held that an agency cannot select or, as here, propose an alternative that fails to accomplish the very purpose and need the agency has articulated The Forest Service should keep the Roadless Rule intact exactly as it is. Do not weaken or repeal this critical policy. National forests are the heart of our public lands. The Roadless Area Conservation Rule protects some of the wildest forests we have left, forests that protect critical wildlife habitat and drinking water for millions. Revoking the Roadless Rule puts landscapes, wildlife, and communities at risk. Not only is the Roadless Rule good policy, it's also wildly popular across the country, with over 600,000 people submitting comments to the US Forest Service last year in support of keeping the rule in place. And more than 20 years ago, the American people overwhelmingly called for our national forests to be protected for future generations. Revoking the Roadless Rule would destroy the natural inheritance we leave for our children.