Comment Analysis · Docket FS-2025-0001

FS-2025-0001-522966

Opposes rescissionA0 noneSubstance 6/24Posted 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

  • Cultural Heritage Indigenous
    • “irreplaceable archaeological sites”
    • “densest concentrations of cultural and historical artifacts”
    • “sacred and historic sites face permanent destruction”
  • Water Quality Quantity
    • “primary source of clean drinking water”
    • “threaten regional water security”
    • “damage delicate riparian habitats”
  • Environmental Protection Biodiversity
    • “natural habitats are severely degraded”
    • “sensitive wildlife habitats”
    • “long-term ecological health”
  • Forest Management Wildfire
    • “human-caused wildfires”
    • “hazardous fuels reduction”
    • “threat of catastrophic wildfire”

What it names

National Forests
Coconino National Forest
Roadless areas
East Clear Creek

The comment

Date: September 30, 2026 To: National Roadless Program Manager, USDA Forest Service Subject: Strong Opposition to the Proposed Rescission of the 2001 Roadless Area Conservation Rule (Docket No. FS-2025-0001 / RIN 0596-AD66) I am writing to express my vehement opposition to the proposed rule to rescind the 2001 Roadless Area Conservation Rule. I strongly urge the U.S. Forest Service (USFS) to retain these crucial protections for our remaining intact backcountry lands. As a resident concerned with the management of the Coconino National Forest and surrounding public lands in Coconino County, Arizona, I believe this rollback will yield exclusively negative impacts on our environment, communities, and fiscal resources. 1. Inadequate Staffing, Budget Cuts, and Off-Road Vehicle (ORV) Abuse The Forest Service lacks the structural capacity, personnel, and budget to manage and regulate existing motorized use, let alone police newly opened backcountry areas. • Existing Damage: Motorized recreational users already have ample access to designated ORV areas. In these "sacrificed" zones, the ground is visibly denuded, soils are heavily compacted and carved up, and natural habitats are severely degraded. • Enforcement Failure: Even in areas where motorized vehicles are legally restricted to existing routes, rules are blatantly and routinely ignored. Unauthorized off-trail driving is common, resulting in severe degradation of wildland areas, sensitive wildlife habitats, and irreplaceable archaeological sites. • Budget Realities: Recent federal budget cuts have left the USFS severely short-staffed. Opening pristine, roadless areas to potential resource extraction and road construction invites unchecked abuse. The agency simply does not have the law enforcement personnel or monitoring resources to prevent illegal motorized incursions into these newly vulnerable zones. 2. Escalating Human-Caused Wildfire Risks and Budget Strain The environmental analysis must fully account for the direct correlation between increased vehicular access and human-caused wildfires. • Ignition Corridors: Opening remote areas to motorized vehicles opens the door to increased human-caused ignitions in areas that are currently difficult for firefighting crews to access quickly. • Fiscal Burden: The national wildfire suppression budget is already profoundly overtaxed. The economic and ecological impacts of catastrophic wildfires are astronomical. • Community Vulnerability: For communities in Coconino County nestled within the wildland-urban interface, increasing the threat of catastrophic wildfire directly endangers homes, human lives, and critical municipal watersheds. 3. Substantive Threats to Coconino County’s Resources In Coconino County, the 50,000 acres of Inventoried Roadless Areas (IRAs)—including ecologically vital zones like East Clear Creek—are irreplaceable. • Archaeological and Cultural Protection: Coconino County holds one of the densest concentrations of cultural and historical artifacts in the nation. Without the strict prohibitions of the 2001 Rule, these sacred and historic sites face permanent destruction from unauthorized off-road driving and resource development. • Watershed Integrity: Our local forests serve as the primary source of clean drinking water for the region. Removing protections will accelerate erosion from logging roads, damage delicate riparian habitats, and threaten regional water security. The 2001 Roadless Rule already contains flexible provisions that allow the Forest Service to perform necessary hazardous fuels reduction and public safety projects without building permanent infrastructure. Rescinding the rule entirely is an unnecessary step that trades long-term ecological health and fiscal responsibility for short-term exploitation. I request that the Forest Service withdraw this proposed rescission and maintain the 2001 Roadless Area Conservation Rule in its entirety. Sincerely, Judy and Pete Weiss

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