Comment Analysis · Docket FS-2025-0001

FS-2025-0001-570232

Opposes rescissionA2 moderateSubstance 11/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment establishes that road construction in the Allegheny Front IRA involves the discharge of fill material into jurisdictional waters under Clean Water Act Section 404 and argues that rescinding the Roadless Act prioritizes short-term economic gains over long-term ecological obligations.

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

Water Quality Quantity
- “Water is a precious resource for all humans”
- “To destroy watersheds now, for short term profits”
- “Clean Water Act Section 404 jurisdiction”
- “discharge of fill material into these streams”
Legal Regulatory Framework
- “NEPA is a success”
- “Clean Water Act Section 404”
- “Do not rescind the Roadless Act”
- “federal agencies would use NEPA as a planning tool”
Environmental Protection Biodiversity
- “long-term ecological obligation”
- “potential environmental consequences”
- “cumulatively major, effects of multiple actions”
- “health and wellness of ALL Americans”

What it names

National Forests: Allegheny National Forest
Roadless areas: Allegheny Front

The comment

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

Dear Ms. Rollins: As a parent, I submit these comments in opposition to a proposed rescission that, in my assessment, inverts the appropriate relationship between short-term economic rationale and long-term ecological obligation. Water is a precious resource for all humans. I want this resource to be valued above all else and my children will need this resource and so will their children. To destroy watersheds now, for short term profits, is incredibly short sighted and does not benefits Americans. Regarding the Allegheny Front in the Allegheny National Forest, Pennsylvania: Waters of the United States flow through the Allegheny Front IRA, Allegheny National Forest, establishing Clean Water Act Section 404 jurisdiction over any activity involving discharge of fill material into these streams. "NEPA is a success — it has made agencies take a hard look at the potential environmental consequences of their actions, and it has brought the public into the agency decision-making process like no other statute. Congress envisioned that federal agencies would use NEPA as a planning tool to integrate environmental, social, and economic concerns directly into projects and programs. However, during the first 25 years of NEPA, application has focused on decisions related to site-specific construction, development, or resource extraction projects. Perhaps the most significant environmental impacts result from the combination of existing stresses on the environment with the individually minor, but cumulatively major, effects of multiple actions over time." — Council on Environmental Quality, Executive Office of the President Every stream crossing required for road construction in the Allegheny Front IRA, Allegheny National Forest, involves placement of fill material — culverts, bridge footings, approach fills — into jurisdictional waters, constituting discharge under Clean Water Act Section 404. Do not rescind the Roadless Act! The Forest Service and U.S Government seems to be focused on short term profit and not the health and wellness of ALL Americans. Very truly yours, Elizabeth Darling CommentID: RLC-20261005-UE9ZOO