Comment Analysis · Docket FS-2025-0001

FS-2025-0001-476611

Opposes rescissionA0 noneSubstance 6/24Posted September 24, 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

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
- “preserving the nations biodiversity”
- “diverse wildlife”
- “protect and maintain this essential Roadless Rule”
Water Quality Quantity
- “clean water”
- “protection of our national roadless forests”
Recreation Tourism Public Use
- “hunting and recreational forest lands”
- “values and benefits to present and future generations”

The comment

As a consulting forester of 40 plus years, sustainability planner and conservationist, I am opposed to the dangerous, non-sensical recession of the vital 2001 USDA FS Roadless Rule enacted in 2001. The federal government must protect and maintain this essential Roadless Rule fully in it strongest form. Protection of our national roadless forests is essential for preserving the nations biodiversity, clean water, diverse wildlife, hunting and recreational forest lands and more. These values and benefits to present and future generations must be secure and maintained in the secure, strong present roadless rule as it is current, vital, successful law. Please protect the roadless rule as strong as it is at present and do not permit any recession. Thank you for considering my public testimony. Sincerely, Daniel R. Plumley Founder Director Totem Consulting Group, LLC 93 Hurricane Road Keene, NY 12942 P.O. Box 746 Keene Valley, NY 12943 (Mail US Post (518) 524-7771 Email: danplumley@totemgroup.us