Comment Analysis · Docket FS-2025-0001

FS-2025-0001-534839

Opposes rescissionA2 moderateSubstance 10/24Owed an answerPosted October 4, 2026 On Regulations.gov

In short: The comment documents that the DEIS identifies specific adverse impacts of the rescission, including increased fire frequency and water quality degradation, while highlighting a gap in the agency's analysis regarding the lack of funding and manpower to implement necessary mitigation measures, and proposes an alternative to expand forest health operations without full rule rescission.

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

A2 moderate: Hard to dismiss — it shows cause and effect.

Owed an answer on Analytical gap, Evidence, Alternative.

Standard dismissals it defeats

Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
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.

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.
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.
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
- “ecological integrity of these lands”
- “adverse impacts to threatened, endangered, or sensitive wildlife and plants”
- “landscape fragmentation”
- “loss of scenic character”
Forest Management Wildfire
- “threaten forest health and exacerbate wildfire risks”
- “increased fire frequency (human-caused)”
- “forest health management activities”
- “vegetative management”
Water Quality Quantity
- “sedimentation and impacts to water quality”
- “drinking-water sources”
Recreation Tourism Public Use
- “reducing primitive or semi-primitive recreational settings”
- “economic losses related to recreation”
- “last remaining places where you can get away from the modern world”
- “great spiritual satisfaction”

What it names

National Forests: Kootenai National Forest

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeAnalytical gapRequest

I am writing in opposition to the proposed 2001 Roadless Area Conservation Rule Rescission. I am a concerned citizen who enjoys recreating on public lands and who cares about the ecological integrity of these lands. I have also worked on trails in Kootenai National Forest as a former member of the Montana Conservation Corps. Given the information provided in the Draft Environmental Impact Statement (DEIS) for the proposed rescission, the reasons for it as published by the USDA are misaligned with the predicted consequences of the rescission. The stated purpose and need for it is to return “decision-making authority to local leaders [to ensure] that issues such as reducing wildfire risks and forest health are addressed based on local conditions rather than a one-size fits all regulation,” however, this action would threaten forest health and exacerbate wildfire risks by putting pressure on rural, local decision-makers who may feel a responsibility to open up lands to irresponsible developments for short-term profits. In the wake of budget cuts to healthcare, food programs, and education, more jobs will be needed to help support rural families and communities, which logging operations and construction projects could potentially provide, but this would come at the cost of worsening long-term environmental conditions. The DEIS states that developments such as constructing new roads, increased timber production, oil, gas and new mining projects would likely result in “increased fire frequency (human-caused), reduction in primitive or semi-primitive recreational settings; sedimentation and impacts to water quality; landscape fragmentation; adverse impacts to threatened, endangered, or sensitive wildlife and plants; loss of scenic character; impacts to tribally important resources; or economic losses related to recreation or non-commodity values of roadless areas,” (22). These effects will be proportionate to how much development occurs and how much mitigation is done to prevent the worst outcomes. This is why the DEIS calls for an increase in forest health management activities if the rescission occurs. However, these kinds of operations seem less likely to occur than ever due to recent and expected budget cuts and layoffs to the Forest Service. Therefore, this rescission should not occur at all, but especially so if there is no commitment, insufficient manpower in the service, nor an actual plan with funding laid out as to how negative impacts can be effectively managed. I fear that this rescission will likely have devastating impacts on those who live near and depend on healthy forests for their own survival, livelihoods, and for a sense of identity and meaning. It would diminish or entirely eliminate the quality of the last remaining places where you can get away from the modern world and explore how wondrous, awesome, and terrifying nature can be. I have found some of these lands to provide great spiritual satisfaction and to destroy them as if they were just an economic resource is, to me, like burning a church or tearing down a temple. We know that new road construction and timber harvesting done irresponsibly is destructive to overall forest health, and so we should not renege on the roadless rule which offers widespread protections from destructive developments across public lands. I would be more favorable to a rule change rather than an entire rule rescission that, all at once, gets rid of protections that have been in place for 25 years. Why can’t we expand operations that are explicitly for the purposes of fire safety, vegetative management, habitat improvement, and any other forest health concerns without at the same time opening our forests up to more industrial activities, and thus to damaging our remaining forests? The reasons for this rescission do not make any sense to me. You say you want one thing, that is, returning decision-making powers to local land authorities in order to be better able to preform forest health operations, but then, in the same move, you are doing something completely antithetical to the purposes of improving forest health, that is, opening public lands to more industrial logging, mining, and construction activities. This misdirection, lying, and deception makes me furious at the whole situation. Stop selling out the American people. Do your jobs as representatives of the American people. Prioritize and protect us and our lands, do not get rid of the 2001 Roadless Rule.