Comment Analysis · Docket FS-2025-0001

FS-2025-0001-519906

Opposes rescissionA0 noneSubstance 4/24Posted September 30, 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
    • “Benefits must continue to accrue to habitats, resident flora and fauna”
    • “57% of vulnerable U.S. wildlife species have suitable habitat in roadless areas”
    • “These natural areas must be protected. There are too few of them left.”
  • Public Opinion Support
    • “more than 99.8% of submitters opposed the rescission”
    • “76% of likely voters support the Roadless Rule”
    • “More than 100 members of Congress have co-sponsored the Roadless Area Conservation Act”
  • Climate Carbon Storage
    • “carbon sequestration”
    • “Benefits must continue to accrue to... carbon sequestration”
  • Recreation Tourism Public Use
    • “human enjoyment of wild places”
    • “I look forward to hiking and birding in two weeks”
    • “44.5 million acres of undeveloped backcountry forestland”

What it names

Works cited
10.1002/ecs2.149210.1016/j.gecco.2021.e01943

The comment

The position set forth in this comment is that rescission is unwarranted and the Rule should be preserved. CommentID: RLC-20260930-NYAKV6 I oppose recission of the Roadless Rule. This Rule has demonstrated its benefits over many years and there is absolutely no justification for rescinding it. Benefits must continue to accrue to habitats, resident flora and fauna, fire prevention, carbon sequestration, and human enjoyment of wild places. Please do not allow the Roadless Rule to be rescinded. Our local roadless areas include areas of Mt. Baker-Snoqualmie National Forest, where I look forward to hiking and birding in two weeks. These natural areas must be protected. There are too few of them left. I submit the following information to support my position. "The Roadless Rule is one of America's most popular conservation measures, and that support has not faded. Prior to its 2001 enactment, more than 600 public hearings were held nationwide and 1.6 million Americans weighed in to call for protection of these forestlands—more comments than any other federal rule had received at the time. When USDA announced its rescission proposal, the compressed 21-day public comment period in late 2025 drew approximately 600,000 additional comments. A detailed roadless.org analysis of the comment record found that more than 99.8% of submitters opposed the rescission. A February 2026 Pew Charitable Trusts national poll found that 76% of likely voters support the Roadless Rule compared to just 13% opposed, with bipartisan backing from 71% of Republicans, 80% of Democrats, and 80% of independents. More than 100 members of Congress have co-sponsored the Roadless Area Conservation Act of 2025 (S.2042 / H.R.3930) to codify the Rule so it could not be rolled back without an act of Congress." "The proposed rollback of the 2001 Roadless Rule jeopardizes 44.5 million acres of undeveloped backcountry forestland managed by the U.S. Forest Service. These forests have only remained intact because of the Forest Service's nearly 25-year-old commitment not to build roads in these areas for harmful activities like major logging operations or oil-and-gas drilling." “Species-level modeling shows 57% of vulnerable U.S. wildlife species have suitable habitat in roadless areas. Adding unprotected roadless areas to protected areas markedly reduces poorly-represented species of conservation concern. — Dietz et al., 2021 (https://doi.org/10.1016/j.gecco.2021.e01943)” “Comparing fire severity across forests under different protection regimes, the study found forests with higher levels of protection had lower severity values even though they are generally identified as having the highest overall levels of biomass and fuel loading. The result contradicts the claim that protected, intact forests are more dangerous fire risks. — Bradley et al., 2016 (https://doi.org/10.1002/ecs2.1492)” Respectfully submitted, Julie Kinder Anacortes, Washington 98221

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