Comment Analysis · Docket FS-2025-0001

FS-2025-0001-465306

Opposes rescissionA1 strongSubstance 14/24Owed an answerPosted September 22, 2026 On Regulations.gov

In short: The comment establishes that the 2001 Roadless Area Conservation Rule is legally required by the National Forest Management Act to maintain co-equal multiple uses, and that rescinding it would degrade water quality, wildlife habitat, and increase wildfire and invasive species risks, thereby urging the selection of Alternative 1.

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 Evidence, 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
- “protect the crucial stream and river headwaters”
- “degrading fish and wildlife habitat and compromising water quality”
- “increasing soil erosion, runoff, and sedimentation”
Wildlife Habitat
- “crucial, unfragmented habitat and corridors for many wildlife species”
- “threatened and endangered species”
- “degrading fish and wildlife habitat”
Environmental Protection Biodiversity
- “maintaining the wilderness, watershed, fish and wildlife values”
- “Roads also are conduits for invasive species”
- “IRAs are necessary to make sure that our forests are not overrun and degraded by invasive species”
Recreation Tourism Public Use
- “Outdoor recreation, which can and does include hunting, fishing, hiking and camping, are compatible with maintaining the IRAs”
- “protect the legally mandated purposes of our National Forest System: outdoor recreation”

What it names

Law cited: 16 U.S.C. 1604

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeEA analysisAnalytical gapEvidenceRequestAlternative

Dear U.S. Service Chief Tom Schulz, Thank you for the opportunity to comment on the proposed recission of the 2001 Roadless Area Conservation Rule. I have reviewed the information posted in the Federal Register docket number FS-2025-0001 / RIN 0596-AD66 and the accompanying Draft EIS. After reviewing those materials, I urge you to choose Alternative 1 outlined in the Draft EIS, which will maintain the current 2001 Roadless Area Conservation Rule. As stated in the Federal Register’s rational for the proposal (Federal Register p. 53828), the National Forest Management Act (NFMA) of 1976 requires that forest plans “shall assure multiple use and sustained yield of National Forest System products and services and include coordination of outdoor recreation, range, timber, watershed, wildlife and fish, and wilderness (16 U.S.C. 1604(e)(1)).” Those uses are co-equal: Extractive uses do not have priority. The current inventoried roadless areas (IRAs) in our National Forest System are crucial for maintaining the wilderness, watershed, fish and wildlife values of our forests. Outdoor recreation, which can and does include hunting, fishing, hiking and camping, are compatible with maintaining the IRAs. The draft EIS states on p. 29 that numerous activities are allowed in IRAs, if not restricted by land management plans or other regulations. “These activities include, but are not limited to, the following: Maintaining existing roads; Constructing or maintaining motorized and non-motorized trails; Engaging in hunting, fishing, hiking, camping, and other recreational uses; Using a motorized vehicle, such as an off-highway vehicle, on a trail open to motorized use; Riding a bike on a trail open to mechanized use; Implementing prescribed burning; and Grazing livestock.” Roadless areas protect the crucial stream and river headwaters upon which many Americans and fish and wildlife depend. Roads will harm those streams and headwaters by increasing soil erosion, runoff, and sedimentation, thereby degrading fish and wildlife habitat and compromising water quality for humans and for fish and wildlife. The National Forest System is also charged with maintaining wilderness, which by definition requires roadless areas. Roadless areas provide crucial, unfragmented habitat and corridors for many wildlife species, including large game animals and threatened and endangered species. Roads also are conduits for invasive species, which threaten all the values that our forests are supposed to maintain: Range, timber, watershed, wildlife and fish, and also wilderness. Invasive grasses such as cheatgrass and buffelgrass, invasive shrubs and also trees increase wildfire risks. Our native plants and animals don’t always have adequate defenses against invasive insects and other animals. IRAs are necessary to make sure that our forests are not overrun and degraded by invasive species. With regard to fire on U.S. National Forests, p. 89 of the Draft EIS states, “ignition density is approximately four times greater on other NFS lands compared to the potentially affected IRAs and wilderness.” Fire is a natural process in North American forests, but the number of human-caused ignitions in our forests is not. Note that the current roadless rule does not bar all roads from IRAs. Table 1 of the draft EIS lists all the circumstances under which a road may be appropriate. In addition, as detailed in the draft EIS on p. 14, determination of exceptions are under local control – the regional forester. Again, I urge you to choose Alternative 1 outlined in the Draft EIS. Most of our National Forest lands are not inventoried roadless areas. Maintaining the 2001 Roadless Area Conservation Rule and the Forest’s IRAs will protect the legally mandated purposes of our National Forest System: outdoor recreation, range, timber, watershed, wildlife and fish, and wilderness. Sincerely yours, Mari Jensen M.S. Renewable Natural Resources Studies University of Arizona