Comment Analysis · Docket FS-2025-0001

FS-2025-0001-535249

Opposes rescissionA0 noneSubstance 1/24Posted October 4, 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

Legal Regulatory Framework
- “not well grounded in law or reason”
- “arbitrary and capricious”
- “failed to provide sufficient scientific or policy justification”
Forest Management Wildfire
- “increasing road construction, increase the likelihood of human-caused wildfires”
- “most human-caused wildfires originate in proximity to road access”
- “USFS already cannot maintain its existing road inventory”
Wildlife Habitat
- “detrimental effects on threatened/endangered species”
- “reducing prime habitat for numerous species, including elk, deer, wolves, bears and mountain lions”
- “increased logging also hurts hunters and anglers”
Public Opinion Support
- “landslide of public support for the rule”
- “The public overwhelmingly supports the Roadless Rule”

The comment

This Administration's proposal to rescind the 2001 Roadless Rule is not well grounded in law or reason. As a legal matter, the process by which the Administration is proposing to rescind the rule is arbitrary and capricious in that it has failed to provide sufficient scientific or policy justification for rescinding the rule - particularly in light of the landslide of public support for the rule when it was initially enacted in 2001. As a practical matter, rescinding the Roadless Rule would, by increasing road construction, increase the likelihood of human-caused wildfires, which our country cannot afford either economically or ecologically. Data shows that most human-caused wildfires originate in proximity to road access. Increased roads would also lead to increased logging, in this case by intentional design. Not only would that have detrimental effects on threatened/endangered species (especially with this Administration's efforts to gut the Endangered Species Act), but increased logging also hurts hunters and anglers by increasing run-off into streams and reducing prime habitat for numerous species, including elk, deer, wolves, bears and mountain lions. The United States Forest Service cannot afford to rescind the Roadless Rule in a literal sense - the USFS already cannot maintain its existing road inventory. Increasing roads will only exacerbate the problem by increasing road maintenance costs and creating more work even after the USFS staff and budget was decimated by this Administration's so-called "Department of Governmental Efficiency" (DOGE), spearheaded by billionaire Elon Musk before he bailed out of that national debacle. The public overwhelmingly supports the Roadless Rule and this Administration has not set forth a reason to rescind it that is grounded in either science, fact, or sound public/fiscal policy. Too many public dollars have already been spent in this effort to rescind the Roadless Rule. I urge you to drop the effort to rescind the rule. Brian Upton 514 Cleveland Missoula, MT 59801