Comment Analysis · Docket FS-2025-0001

FS-2025-0001-480159

Opposes rescissionA1 strongSubstance 4/24Owed an answerPosted September 24, 2026 On Regulations.gov

Small family — One letter sent by 3 to 9 people, copied or lightly reworded. One of 4 submissions in its group. See the letter, its submissions and topics.

Carries the letter's score — A copy of a family's letter; it holds the score and answerability level of the letter it sent.

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. This rating is the one its shared letter earned.

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.
  • 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

What it names

Law cited
90 FR 42179

The comment

Subject: Public Comment Supporting the “No Action” Alternative – Opposing the Rescission of the 2001 Roadless Area Conservation Rule To: USDA Forest Service Planning Team Re: Notice of Intent to Rescind the 2001 Roadless Area Conservation Rule (90 FR 42179) Dear USDA Forest Service Planning Team, As an active trail advocate, mountain biker, and member of the Southern Off-Road Bicycle Association (SORBA), I am writing to express my strong opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule. I urge the Forest Service to select the “No Action” alternative, maintaining the vital protections provided by the 2001 Roadless Rule. Inventoried Roadless Areas (IRAs) protect intact watersheds, preserve natural landscapes, prevent harmful forest fragmentation, and safeguard irreplaceable backcountry mountain biking experiences.

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