Comment Analysis · Docket FS-2025-0001

FS-2025-0001-499985

Opposes rescissionA0 noneSubstance 9/24Posted September 28, 2026 On Regulations.gov

Small family — One letter sent by 3 to 9 people, copied or lightly reworded. This comment stands for 4 submissions in its group; the sender added words of their own. See the letter, its submissions and topics.

In short: The comment establishes that the commenter has standing based on recreational use of the El Dorado and Stanislaus National Forests, and documents deficiencies in the DEIS regarding the assessment of national-scale environmental effects, the adequacy of the Tongass National Forest analysis, and incomplete Tribal consultation, while requesting the selection of the No Action Alternative.

Scored as the letter — The shared letter of a family, scored once for everyone who sent it.

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
- “wildlife habitat”
- “intact forests”
- “landscape fragmentation”
- “habitat connectivity”
Water Quality Quantity
- “clean water”
- “regional watersheds”
- “drinking-water sources”
Recreation Tourism Public Use
- “hiking and fishing”
- “remote areas away from cars”
- “solitude”
Tribal Sovereignty
- “Tribal consultation remains incomplete”
- “Tribal concerns about subsistence”
- “cultural resources”

What it names

National Forests: Stanislaus National Forest Tongass National Forest

Attachments

1 file. Counts as 1 — Counts as one: The attachments enclose no one else's submissions; the comment counts as one.

Own letter

The comment

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

Secretary Brooke Rollins U.S. Department of Agriculture 201 14th Street SW Washington, DC 20250 Thomas Schultz Chief, U.S. Forest Service 1400 Independence Ave., SW Washington, D.C. 20250-0003 Re: Docket No. FS-2025-0001 - Comments on the 2001 Roadless Area Conservation Rule Rescission Draft Environmental Impact Statement (DEIS) Dear Secretary Rollins and Chief Schultz: I strongly urge USDA to keep the 2001 Roadless Area Conservation Rule (Rule) intact, select the No Action Alternative, and revise the DEIS as stated below. I spend time in Rubicon in the El Dorado National Forest and the Tuolomne River in Stanislaus National forest and deeply value Inventoried Roadless Areas there]. I enjoy hiking tand fishing here. This place matters to me because I enjoy getting out in remote areas away from cars and traffic]. They provide clean water, wildlife habitat, recreation, solitude, and increasingly rare intact forests. The current Rule already allows substantial forest management, including prescribed fire and other hazardous-fuels reduction. While USDA claims rescission would reduce wildfire risks, the DEIS cites research that 1) the lack of roads has not prevented fire prevention or protection measures, and 2) acknowledges that almost 90% of wildfires are human caused and more than four times likely to ignite near a road. If specific constraints exist, USDA should identify and address those narrow constraints rather than remove the Rule’s nationwide protections. USDA has not adequately assessed the reasonably foreseeable national and regional environmental effects of its decision to eliminate the Rule’s protections across 44.7 million acres of public lands. Deferring NEPA review to future site-specific individual projects will not address the regional and national consequences of rescission. While later reviews may evaluate individual projects, they would not address foreseeable programmatic impacts at scale from landscape fragmentation, habitat connectivity, native plants and invasive species. interstate or inter-forest migration corridors, or regional watersheds. USDA should assess now where national rescission would put intact habitat, wildlife movement, and native plant communities at greatest risk, and where added roads and timber harvest could most threaten watersheds and drinking-water sources. Rescission would also remove protections from 9.3 million acres in the Tongass National Forest, relying on the 2020 Alaska Roadless Rule Final EIS, but it has not demonstrated the earlier environmental analysis adequately evaluates rescission. Tribal consultation remains incomplete. USDA should fully consider Tribal concerns about subsistence, cultural resources, fish and wildlife, and intact landscapes before making a final decision. I urge you to keep the national protections of the Rule in place and reassess the reasonably foreseeable effects now. attached file(s)