Comment Analysis · Docket FS-2025-0001

FS-2025-0001-461649

Opposes rescissionA1 strongSubstance 12/24Owed an answerPosted September 21, 2026 On Regulations.gov

In short: The comment establishes that the proposed rescission of the 2001 Roadless Rule fails to adequately protect water supplies under the Organic Act, lacks sufficient staffing for local planning, and ignores climate change impacts, specifically requesting that the rule remain in place for the Tongass National Forest unless timber is restricted to domestic use.

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.
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

Water Quality Quantity
- “water supply of the aquifer where our domestic well is located originates on the lands of the Santa Fe National Forest”
- “protection of the forests and the water supply originating on the Forest lands”
- “roadless rule should not be rescinded unless it can be shown that the production of good quality water is protected”
- “ignoring the impact of this activity on wildlife habitat and water resources”
Climate Carbon Storage
- “current administration has ignored the adverse impacts of climate change on water supply and Forest health”
- “construction of roads in the Forest will not mitigate the impacts of climate change”
- “failure to address climate change... cannot be used to justify increased exploitation”
Governance Policy Process
- “Forest Service has not allowed adequate time for review and comment”
- “Will the current administration commit to ensuring that a fully staffed workforce will be available”
- “management decisions are made on an ad hoc basis... without the benefit of precedent or consistency”
- “use of the Executive Orders... as a basis of fact or truth is neither appropriate nor sufficient”
Wildlife Habitat
- “bias toward private exploitation of our natural resources on public lands while ignoring the impact of this activity on wildlife habitat”
- “2001 Roadless Rule for the Tongass National Forest should remain in place”

What it names

National Forests: Santa Fe National Forest Tongass National Forest
Law cited: Executive Order 14225

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequestAlternativeLegal

I am submitting the following comments on the proposed rule that would rescind the 2001 Roadless Area Conservation Rule (2001 Roadless Rule) on National Forest System lands, including the Tongass National Forest. Reference RIN 0596–AD66, published in the Federal Register August 20, 2026. I support the no action alternative and believe that the current administration’s reasons for eliminating the Roadless rule do not support elimination of the rule. In addition, the Forest Service has not allowed adequate time for review and comment on this proposed rule. My family and I have resided within a watershed arising in the Santa Fe National Forest, within six miles of the Forest boundary, for over 40 years. The water supply of the aquifer where our domestic well is located originates on the lands of the Santa Fe National Forest. We are directly impacted by the effects of Forest land management activities. 1.Any Forest land use activity must be in accordance with intention of the Forest Service Organic Administration Act of 1897, which requires the protection of the forests and the water supply originating on the Forest lands, including the lands upstream of our well. The Draft Environmental Impact Statement’s discussion of the Organic Act focuses on the impact of road construction for the principal purposes of mineral resource extraction and logging while the protection of water supply originating on Forest lands is treated as a secondary purpose. The roadless rule should not be rescinded unless it can be shown that the production of good quality water is protected. 2.The proposed rule seeks to rely upon the flexibility of the local land management planning process, through local decision making and planning without restrictive and unnecessary national prohibitions, according to the Federal Register Notice. Will the current administration commit to ensuring that a fully staffed workforce will be available to support this local decision-making process? Without that assurance, the planning process may fail. The elimination of a single national rule and implementation of local management decisions will increase uncertainty because management decisions are made on an ad hoc basis, at each district office, without the benefit of precedent or consistency to guide planning decisions. 3.The use of the Executive Orders referred to in the Rule Notice (e.g., Executive Order 14225) as a basis of fact or truth is neither appropriate nor sufficient justification for rescission of the Roadless Rule. The current administration has demonstrated a bias toward private exploitation of our natural resources on public lands while ignoring the impact of this activity on wildlife habitat and water resources. 4.The notice claims that the rescission is needed to allow greater flexibility in addressing the effects of drought, insect infestations and wildfire that did not exist when the Roadless Rule was adopted in 2001. This current administration has ignored the adverse impacts of climate change on water supply and Forest health. The construction of roads in the Forest will not mitigate the impacts of climate change. This failure to address climate change on the part of the current administration cannot be used to justify increased exploitation of our natural resources. 5.The 2001 Roadless Rule for the Tongass National Forest should remain in place, unless all of the timber harvested from this Forest will be solely for domestic use and not exported.