Comment Analysis · Docket FS-2025-0001

FS-2025-0001-453367

Opposes rescissionA1 strongSubstance 8/24Owed 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 Analytical gap, 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.
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.
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.
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.

Topics

Environmental Protection Biodiversity
- “irreparable damage to protected ecosystems and native wildlife”
- “Deforestation will destroy our public lands and harm critical wildlife”
- “devastating toxic environmental pollution”
- “Irreversible loss of nature”
Economic Impact Fiscal
- “US does not have enough lumber mills in order to justify destroying our public lands”
- “record high diesel prices which is projected to lead to devastating effects downstream”
- “destroying public lands and jobs for hard-working Americans for a projected $4-10 million in revenue is inherently a lose-lose scenario”
- “benefiting the economy as a whole”
Recreation Tourism Public Use
- “$1.3 trillion dollar outdoor recreation economy supports millions of jobs”
- “devastate rural economies that depend on outdoor recreation”
- “all who enjoy it”
- “protect what makes our country great for generations to come”
Forest Management Wildfire
- “more public access via new roads will increase wildfire risk”
- “National Forest Service currently cares for over 300,000 miles of road, of which there is a large maintenance backlog”
- “adequately staff and fund the National Forest Service”

What it names

Law cited: EO 14154 EO 14225

The comment

In August 2025, I and thousands of other people submitted comments on the proposal from USDA to rescind the Roadless Rule. Analysis of this publicly available data showed that 99% of those comments were in opposition of removing the Roadless Rule. Despite this overwhelming opposition and mountains of evidence to support the clear benefits of the Roadless Rule, I am here again in 2026 writing to keep the 2001 Roadless Rule in place as it is. Below are my main concerns with the current proposal 91 FR 53827: 1) EO 14225 is listed as a reason to support rescinding the Roadless Rule and states that the US has enough timber for domestic demand, but fails to provide any evidence for this claim. The logging industry is complex, and the US does not have enough lumber mills in order to justify destroying our public lands in the name of profit. In order to ramp up US-based lumber mill output we would need to invest into significant upgrades to existing mills as they would not be capable of handling old-growth forest logs. Current economic policy and tariffs cause this option to be untenable due to increased costs. American forests are also primarily pine, which is a very soft wood not ideal for building and as such we are reliant on hardwoods grown in colder climates like Canada. In order to address our lumber needs, we should instead address the harms of current economic/tariff policy. 2) Rescinding the Roadless Rule would open up public land for harmful resource depletion. EO 14154 is fundamentally flawed as it fails to account for our most abundant renewable energy sources such as water, wind, and solar. Oil, coal, and natural gas are not reliable energy sources as they are not renewable; once it is gone, all we are left with is a devastated landscape filled with pollutants that harm the American public. Reliance on fossil fuels is short-sighted and leads to increased costs for American consumers; under current policy, we are now experiencing record high diesel prices which is projected to lead to devastating effects downstream in the supply chain for necessities like food, medicines, and other goods. There is an argument that utilizing American oil will reduce reliance on crude oil from other countries, but US oil is sweet crude oil which our refineries are not equipped to process efficiently, so even if we do ruin our public lands to extract oil from them, we will see little to no benefit. As seen with logging, the costs associated with upgrading refineries is likely too steep to justify doing this. As I have family in West Virginia, I have seen the devastating effects of fracking and coal production firsthand and support phasing these modalities of energy production out entirely in order to protect our communities from cancer and devastating toxic environmental pollution. The future-oriented, evidence based solution to our energy concerns is diversification into renewable energy which will benefit the American public through providing renewable options for domestic energy while also protecting their health and their public lands. It will also allow American businesses to innovate and create new renewable energy products, benefiting the economy as a whole. 3) This proposal is devastating to the environment and all who enjoy it. Deforestation will destroy our public lands and harm critical wildlife. The National Forest Service currently cares for over 300,000 miles of road, of which there is a large maintenance backlog. Why is it imperative to add more roads to protected public land when we cannot take care of the existing ones? Additionally, more public access via new roads will increase wildfire risk. Irreversible loss of nature and important tribal lands aside, the $1.3 trillion dollar outdoor recreation economy supports millions of jobs throughout the country; destroying public lands and jobs for hard-working Americans for a projected $4-10 million in revenue is inherently a lose-lose scenario.The simple solution to the problems the National Forest Service currently faces in regards to land stewardship is not to rescind the Roadless Rule, but to adequately staff and fund the National Forest Service so their needs can be properly addressed. In summary, I strongly oppose the current proposal to rescind the Roadless Rule as it is based on flawed assumptions and data, would cause irreparable damage to protected ecosystems and native wildlife, and would devastate rural economies that depend on outdoor recreation. Public lands are not for sale, and the 2001 Roadless Rule should remain as it is today. Alternative unbiased evidence based solutions as described above should be considered to benefit our nation and protect what makes our country great for generations to come. I will be supporting any legislation and litigation that will keep the 2001 Roadless Rule intact, and will advise my fellow outdoorsman to do the same.