Comment Analysis · Docket FS-2025-0001

FS-2025-0001-491881

Opposes rescissionA0 noneSubstance 5/24Posted September 28, 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

  • Forest Management Wildfire
    • “decrease wildfire risk”
    • “rescinding the Roadless Rule would decrease wildfire risk”
    • “potential roads... will likely increase the incidence of wildfires”
    • “areas protected under the Roadless Rule burn at the same rate”
  • Environmental Protection Biodiversity
    • “destruction of our old growth forests”
    • “awe and serenity one experiences when in nature”
    • “hiking among towering trees that are centuries old”
    • “devastating to lose this part of our history and heritage”
  • Scientific Research Evidence
    • “absent... any data from ecological and forestry scientists”
    • “performed my own investigation”
    • “information that contradicts what was presented”
    • “Humans are a major cause of wildfires”

What it names

Works cited
10.1073/pnas.1617394114Healey 2020

The comment

I am writing as a concerned citizen, California resident, and nature enthusiast. I was alarmed by the recent proposal to rescind the Roadless Rule. I have read the 8/18/2026 USDA press release (https://www.usda.gov/about-usda/news/press-releases/2026/08/18/usda-acts-remove-roadless-rule-restrictions-exacerbate-rising-wildfire-risk) on the rationale behind their proposal, and I strongly disagree. The USDA press release cites an effort to bring decision-making back to local forest services and to assist in decreasing wildfire risk. However, what is absent in the press release is any data from ecological and forestry scientists about whether repealing the Roadless Rule would decrease wildfire risk. What is also absent from the press release are statements from local forest managers (not state governors, but statements from state forest managers) about instances where the current Roadless Rule has significantly harmed their overall ability to care for the land. It is absolutely ridiculous to call for rescinding the Roadless Rule without presenting all this information to the American public. When I performed my own investigation, I found information that contradicts what was presented in the USDA press release. Humans are a major cause of wildfires, and any potential roads that are built as a result of rescinding the Roadless Rule will likely increase the incidence of wildfires. Additionally, areas protected under the Roadless Rule burn at the same rate as areas that do not, so it seems illogical for the USFS to argue that rescinding the Roadless Rule is an effective means of risk reduction. https://www.pnas.org/doi/10.1073/pnas.1617394114 https://iopscience.iop.org/article/10.1088/1748-9326/aba031 Finally, I am worried that removal of the Roadless Rule is the canary in the coal mine for excessive logging and destruction of our old growth forests. As a California resident, there are no words to describe the awe and serenity one experiences when in nature and hiking among towering trees that are centuries old. These forests have seen the creation of America, have lived through our national history with us, and are now so uncommon in the world around us. It would be devastating to lose this part of our history and heritage.

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