Comment Analysis · Docket FS-2025-0001

FS-2025-0001-552388

Opposes rescissionA2 moderateSubstance 12/24Owed an answerPosted October 4, 2026 On Regulations.gov

In short: The comment documents that the proposed rule fails to acknowledge that existing roadless rules already permit timber harvest for forest health, ignores the economic and ecological trade-offs of exporting old-growth timber, and omits analysis of water quality impacts and cumulative effects from other administration actions, while proposing specific alternative exceptions for fuels management and wildland-urban interface roads.

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
- “old-growth forests, which are more resilient to pests, fire, and other disease”
- “clean water, healthy wildlife populations, backcountry recreation, and other benefits”
- “exporting our remaining stands of old growth”
- “intact landscapes that support millions of dollars in commercial fishing”
Water Quality Quantity
- “clean water”
- “maintain all of its roads so they are safe for American people and so that they do not cause problems for streams and fish”
- “significant effects that roads can have on water quality and fish”
- “warming stream water temps”
Recreation Tourism Public Use
- “backcountry recreation”
- “roadless areas are extremely important to American recreationists and other backcountry users”
- “hunting and fishing and gathering and subsistence”
- “resident and visitor fishing activities that are extremely important to the economies of Southeast Alaska communities”
Forest Management Wildfire
- “roadless rule already allows timber harvest and removal to improve forest health/reduce fuels”
- “majority of wildfires are human-caused, which means road access to more areas could exacerbate wildfire risk”
- “forests that truly need more active management are already close to existing roads”
- “strategically placed roads ... can improve suppression effectiveness near communities”

What it names

National Forests: Chugach National Forest

The comment

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

Your rationale for the proposed rule relies very heavily on the "need" to "address overgrown and fuel-loaded national forests" (91 FR 53828). Yet, the proposed rule is silent on the fact that the roadless rule already allows timber harvest and removal to improve forest health/reduce fuels. In fact, the Chugach National Forest (which I am most familiar with) has treated thousands of acres of beetle-killed forest in inventoried roadless areas. The vast majority of lands covered by the 2001 Roadless Rule are old-growth forests, which are more resilient to pests, fire, and other disease than forests that have been harvested. I would think that the forests that truly need more active management are already close to existing roads, and would be accessible from the roads or by using temporary access mats or trails, all of which the Rule would allow (and the Chugach did just that). Prior rules, including the 2020 Alaska rule and the 2023 rule rescinding the 2020 rule) acknowledged that temporary access mats and motorized trails were not prohibited in roadless areas). If more remote areas truly need to be accessed, then why not simply add an additional exception to the road construction prohibition that would allow access for fuels management when certain conditions were met? The Rule already provides for emergency access. You also downplay your own science that shows the majority of wildfires are human-caused, which means road access to more areas could exacerbate wildfire risk. Your proposed rule also talks about the need to increase timber production, yet it does not acknowledge that the vast majority of American mills have retooled to process second growth timber. Does this mean that old growth timber that would become available for harvest would be exported? This happens quite a bit in Alaska, on the Tongass. In fact, it is often the only way to make a proposed sale appraise positive (allowing export of old growth). Where is the discussion of the trade offs associated with exporting our remaining stands of old growth? I am sure the vast majority of American people would prefer that our old growth forests remain intact for the clean water, healthy wildlife populations, backcountry recreation, and other benefits they provide. Regarding access for mineral exploration and development, the 2001 Rule (and the 2020 and 2023 rules) are very clear that mining law provides a statutory right of access for holders of mining claims, and the Rule recognizes those rights. I worked in Alaska for over 30 years, and not once did the Forest Service ever deny requested access for mineral exploration or mine development. Your proposal recognizes a $6.9 billion dollar deferred maintenance funding gap. I suspect it is much higher than that, and this has been an issue for the Forest Service for decades, long before the 2001 Rule. In fact, it was one of the listed reasons for the rule, yet your proposal does not address why it is no longer a concern to the agency. Why not? Where will the money for new construction come from? And where will the agency find the money to maintain all of its roads so they are safe for American people and so that they do not cause problems for streams and fish? Your proposed rule reference 9.8 million acres of wildlands-urban interface, where "strategically placed roads ... can improve suppression effectiveness near communities and critical infrastructure" (at 53829). Again, why not add an additional exception for such roads, rather than rescind a rule that has proven to be effective for over 25 years now? Rescinding the Rule will have a much greater effect on recreation and tourism than your proposal acknowledges, and the vast majority of public comments on the 2020, 2023, and the current proposal support the fact that roadless areas are extremely important to American recreationists and other backcountry users (hunting and fishing and gathering and subsistence). The 2020 and 2023 Alaska rules acknowledged the significant effects that roads can have on water quality and fish, yet your proposal is silent on those effects. For Alaska specifically, roadless areas provide expansive, intact landscapes that support millions of dollars in commercial fishing, as well as significant number of resident and visitor fishing activities that are extremely important to the economies of Southeast Alaska communities. In fact, fishing and tourism are THE economic drivers in Southeast Alaska. Any effect on fish would have a significant effect on these industries, and, combined with other issues such as warming stream water temps, changes in ocean temperature and currents, increasing landslide frequency, and other climate-related effects, could be catastrophic for Alaska fisheries. Your proposed rule is silent on the several other actions the Trump administration is proposing on public lands across the United States, especially in the west. These actions will have significant cumulative effects.