Comment Analysis · Docket FS-2025-0001

FS-2025-0001-541125

Opposes rescissionA0 noneSubstance 7/24Posted October 4, 2026 On Regulations.gov

In short: The comment documents that the rescission proposal lacks meaningful public engagement and sufficient comment periods, while citing specific national forests and Forest Service data to demonstrate the rule's effectiveness in protecting watersheds and biodiversity.

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
- “extensive biodiversity teeming within the lands”
- “protecting these precious areas”
- “biodiversity, and ecosystem integrity”
- “limiting road construction and large-scale logging”
Water Quality Quantity
- “provide clean drinking water”
- “protect watersheds”
- “watersheds within roadless areas are far more likely to be in 'properly functioning' condition”
Governance Policy Process
- “lacked meaningful public engagement”
- “extend the comment period to 120 days for a fair and transparent process”
- “refusing to actively seek out the perspectives of indigenous communities”
- “failure to engage with public voices”
Recreation Tourism Public Use
- “world-class recreation opportunities”
- “hiking, fishing, climbing, and more”
- “Reveling in the presence of not only the physical environment itself”

What it names

National Forests: George Washington National Forest Gila National Forest Tongass National Forest

The comment

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

Dear Secretary Rollins and Chief Schultz, As Members of Congress representing a broad range of communities, stakeholders, and outdoor interests, we write in strong support of the U.S. Forest Service’s Roadless Area Conservation Rule (“Roadless Rule”) and in firm opposition to the Department of Agriculture’s proposal for rescission. We urge the Department to halt this effort and instead focus on effective implementation of this longstanding and successful policy. As a denizen of the state of California, having recently moved to Oregon, I have witnessed the ineffable breadth of different ecosystems and wilderness at large, and the quintessential necessity of protecting these precious areas. The most formative aspects of my life stem from existing in outdoor wilderness via hiking, fishing, climbing, and more. Reveling in the presence of not only the physical environment itself, but also the extensive biodiversity teeming within the lands has been instrumental in molding myself and my valuable relations with others. Beyond a mere recreational context, there is an inextricable link with these ecosystems, as they instill the fruits necessary to center and better oneself, their connection to the world, and their connections with others, as my closest friends and family are linked by this great unifier. Due to this lifelong connection to preserving and living in tandem with wilderness, I am stupefied by the proposal to repeal the Roadless Rule. Since its adoption in 2001, the Roadless Rule has served as a cornerstone of public lands conservation, now protecting approximately 44 million acres of National Forest System lands across 37 states. These areas provide clean drinking water, critical wildlife habitat, carbon storage, and world-class recreation opportunities. Iconic landscapes such as the Tongass National Forest in Alaska, the Gila National Forest in New Mexico, and the George Washington National Forest in Virginia exemplify the ecological, cultural, and economic importance of these lands. The Roadless Rule was developed through one of the most robust public processes in federal rulemaking history. The Forest Service received 1.6 million public comments - approximately 95 percent in support - and held over 600 public meetings nationwide. In contrast, the current rescission effort has lacked meaningful public engagement. The Department provided just 21 days for public comment on the Notice of Intent in 2025 and has yet to hold any public meetings. Despite these limitations, more than 600,000 comments were submitted, with over 99 percent opposing rescission. This overwhelming and bipartisan public support underscores the continued popularity and importance of the Roadless Rule. Unsurprisingly, at just 30 days, the ongoing comment period for the DEIS and proposed rule is equally insufficient, and we encourage the USFS to extend the comment period to 120 days for a fair and transparent process. Looking past the objective value of the Roadless Rule, and my individual anecdotal experiences, the prospect of repealing this protection would be immensely counterproductive and disrespectful to indigenous communities nationwide. When the Roadless Rule was initially posited, there were 600 congregational meetings held in the intention to include tribes, local government, industry, conversation organizers, and more, however, the proposal to repeal the rule should extend the same formality in order to truly gauge the communal perspective of the proposal. By refusing to actively seek out the perspectives of indigenous communities, we broach their way of life through severe consequences/repercussions as a result of this proposal. This failure to engage with public voices to determine what is best for local communities and indigenous populaces further bolsters the inefficiency and lack of foresight in this proposal to repeal the Roadless Act. The enduring support for the Roadless Rule is rooted in its clear and measurable benefits. Over the past 25 years, the rule has helped protect watersheds, biodiversity, and ecosystem integrity by limiting road construction and large-scale logging in undeveloped areas. Forest Service data show that watersheds within roadless areas are far more likely to be in “properly functioning” condition compared to those outside of them, which are more often classified as “at risk” or “impaired.” After 25 years of successful implementation, the conclusion is clear: the Roadless Rule is effective, widely supported, and essential to responsible forest management. Rescinding it would undermine decades of progress and impose unnecessary environmental and fiscal costs. I respectfully urge the Department to end its unjustified rescission of the Roadless Rule. Regards, Vikram Subramaniam Student at the University of Oregon