Comment Analysis · Docket FS-2025-0001

FS-2025-0001-570242

Opposes rescissionA3 weakSubstance 10/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment establishes that the commenter, a volunteer for a licensed wildlife rehabilitation center and recreationist, opposes the rescission of the 2001 Roadless Rule based on USFS data indicating harm to 327 threatened and endangered species, increased wildfire risk, water pollution costs estimated at up to $10 billion, and $6.1 million in annual recreation losses, while asserting that the agency failed to account for these costs in the Docket.

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

A3 weak: Substantive, but easier to set aside.

Owed an answer on Evidence.

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

Wildlife Habitat
- “harm wildlife by removing habitat”
- “harm 327 threatened and endangered species”
- “diversity of plant and animal communities”
Water Quality Quantity
- “threaten public drinking water by polluting headwaters”
- “road construction and logging create sediment pollution”
- “contaminated drinking-water for millions of people downstream”
Forest Management Wildfire
- “increase wildfires”
- “more roads lead to more wildfires”
- “building roads in roadless areas is likely to result in more fires”
Economic Impact Fiscal
- “result in measurable economic losses”
- “estimate of up to $10 billion dollars”
- “losses in economic benefit to recreationists are estimated to be $6.1 million annually”

Attachments

6 files. Counts as 445 — Counted from the files: The enclosed submissions were counted from the files themselves.

Own letter
Enclosed submissions
Supporting material
Own letter
Own letter
Own letter

The comment

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

My name is Juliette, and I am a proud American citizen, registered Independent, newlywed, and volunteer for a licensed wildlife rehabilitation center. I share the Department's passion for "ecological integrity (including air, soil, and water), sources of public drinking water, diversity of plant and animal communities (including federally listed threatened and endangered species), sustainable recreation, scenic character, and protection of cultural and historic resources" as described in Docket (FS-2025-0001). I am commenting today due to this shared passion, my experience working in the field of wildlife rehabilitation, and personal history as a recreationist interested in protecting the wildlife tourism industry. The proposed rescission of the 2001 Roadless Area Conservation Rule (2001 Roadless Rule) would: harm wildlife by removing habitat and increasing wildland-urban interface, increase wildfires, threaten public drinking water by polluting headwaters, and result in measurable economic losses. First, wildlife relies on wildlands. Per the US Forest Service’s own Draft Environmental Impact Statement, repealing the 2001 Roadless Rule is likely to harm 327 threatened and endangered species. Second, per the 2022 US Forest Service study, more roads lead to more wildfires (attached as pdf). This study shows that half of all human-caused wildfires start 1.5 miles from a road. An additional article in the scientific journal Fire Ecology (attached as pdf) shows that building roads in roadless areas is “likely to result in more fires.” Who will bear the financial burden of putting out these fires, and what will the increased costs be? The Department has failed to account for these costs in Docket (FS-2025-0001). Third, per the US Forest Service's "Water Facts" (attached as a pdf) national forests provide the largest source of municipal drinking water in the United States, serving over 60 million people in 33 states. As noted in the US Forest Service General Technical Report SRS-39 (attached as a pdf), road construction and logging create sediment pollution in rivers and streams, leading to contaminated drinking-water for millions of people downstream. The Department has not adequately described the associated costs of needing to clean and filter this polluted water for millions of Americans, with one estimate of up to $10 billion dollars. This amount is based on the cost of building a filtration plant in New York City, as listed in the New York Times (article attached as a pdf). Of course, polluted drinking water will also harm the health of Americans and lead to higher health care costs. Protecting the general welfare of the public is one of the founding principles of the U.S. Constitution; it is clear that rescinding the Roadless Rule is unconstitutional as doing so would pollute the drinking water of millions of Americans, which directly harms the general welfare of the public. Fourth, per Docket (FS-2025-0001), losses in economic benefit to recreationists are estimated to be $6.1 million annually, adding to the financial losses from increased wildfires and polluted drinking water. Also listed in Docket (FS-2025-0001) is the current $6.9 billion deferred maintenance backlog of existing roads and bridges. Due to the analysis above based on relevant research from the US Forest Service and leading science, I recommend retaining the existing 2001 Roadless Rule (“No Action”). To recap, I am a proud American citizen that strongly opposes rescinding the 2001 Roadless Rule, because doing so would harm wildlife, increase wildfires, pollute drinking water for millions of Americans, and result in billions of dollars of economic losses (from mitigating increased wildfires and polluted drinking water and resulting health care costs, decreasing recreationism and tourism, and adding to the $6.9 billion deferred maintenance backlog of existing roads and bridges). I recommend retaining the existing 2001 Roadless Rule (“No Action”).