Comment Analysis · Docket FS-2025-0001

FS-2025-0001-549648

Opposes rescissionA2 moderateSubstance 14/24Owed an answerPosted October 4, 2026 On Regulations.gov

In short: The comment documents the commenter's personal reliance on specific roadless areas in Nevada, Arizona, Washington, and Idaho, and asserts that the Draft EIS fails to justify the loss of these areas by citing research on wildfire ignition rates, agency data on limited timber benefits versus high maintenance costs, and the EIS's own admission of adverse effects on Tribal rights.

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.

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

Recreation Tourism Public Use
- “backpacking, hiking and occasionally rappelling in remote country”
- “no motor vehicle noise, no sign of other people”
- “recreation economy that depends on undeveloped backcountry”
- “ends solitude and quiet for every later visitor”
Environmental Protection Biodiversity
- “Wildlife and water depend on intact habitat”
- “Roadless areas provide core habitat and connecting corridors”
- “effect on threatened and endangered species”
- “shelter salmon spawning habitat”
Forest Management Wildfire
- “Roads increase wildfire ignitions”
- “fires are about four times more likely to start near a road”
- “human-caused wildfires could become more frequent”
- “add ignition sources to remote forest where fire response is slowest”
Governance Policy Process
- “The public process is too short”
- “comment period is a fraction of the time the 2001 rule received”
- “Draft EIS concedes that full rescission carries the greatest potential for adverse effects on Tribal rights”
- “The 2001 rule has worked for 25 years”

What it names

National Forests: Olympic National Forest Tonto National Forest

The comment

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

October 2, 2026 Director, Ecosystem Management Coordination USDA Forest Service 201 14th Street SW, Mailstop 1108 Washington, DC 20250-1124 Re: Docket FS-2025-0001, Special Areas; Roadless Area Conservation, Draft Environmental Impact Statement. Comment in opposition to rescission; support for Alternative 1 (No Action) Dear Director: I oppose the proposal to rescind the Roadless Area Conservation Rule, and I urge the Forest Service to select Alternative 1, the No Action alternative, in Docket FS-2025-0001. I live in Las Vegas and spend a large part of every year backpacking, hiking and occasionally rappelling in remote country across the western United States. I am a user of the backcountry, not a visitor to its trailheads, and the experience I value most is the one roadless land exists to protect: a place with no motor vehicle noise, no sign of other people, and a view of land that looks as it did centuries ago. That experience is rare and cannot be rebuilt. In Washington I hiked 20 miles into the Olympic wilderness and looked out over untouched country to the horizon. In Idaho's Sawtooth range I hiked deep into old-growth forest and slept under skies with no light pollution. Idaho has its own roadless rule, which this proposal leaves in place, so I raise the Sawtooth only to show what intact backcountry offers. I am asking that the same protection stay in place in the states where it is now at risk. Those states include the places I visit most. In Arizona, the Arizona National Scenic Trail crosses the Mazatzal and Boulder roadless areas of the Tonto National Forest, part of roughly 1.17 million acres of inventoried roadless land in the state. Near my home, Nevada has more than 3 million acres of inventoried roadless land across the Humboldt-Toiyabe and Inyo National Forests and the Spring Mountains National Recreation Area. In Washington, roadless lands on the Olympic National Forest border the park and shelter salmon spawning habitat. In Utah, about 4 million acres of national forest would lose protection. A road, a clear-cut or a mine ends solitude and quiet for every later visitor, and no restoration brings them back. The Draft EIS does not justify that loss, for these reasons. Roads increase wildfire ignitions. Research in Fire Ecology found that fires are about four times more likely to start near a road than in a roadless area, and the agency's own analysis acknowledges that human-caused wildfires could become more frequent if roads open this terrain to vehicles and campfires. The rescission would add ignition sources to remote forest where fire response is slowest. The benefit is small and the cost is large. As reported from the agency's own figures, rescission would raise national timber harvest by only about 5 to 10 percent, while the Forest Service already carries a road maintenance backlog of billions of dollars. Adding roads to the least accessible land in the system adds to a bill the agency cannot pay. The Final EIS should weigh that cost against the recreation economy that depends on undeveloped backcountry. Wildlife and water depend on intact habitat. Roadless areas provide core habitat and connecting corridors, and road construction is a leading source of sediment in streams. The Final EIS should state the effect on threatened and endangered species and on salmon streams, area by area. The public process is too short. The comment period is a fraction of the time the 2001 rule received, and the Draft EIS concedes that full rescission carries the greatest potential for adverse effects on Tribal rights and interests. The 2001 rule has worked for 25 years and still leaves room for fire management and local decisions. I ask the Forest Service to retain it, to select Alternative 1, and to respond in the Final EIS to the specific concerns above. Respectfully, Avid Outdoorsman