Comment Analysis · Docket FS-2025-0001

FS-2025-0001-571262

Opposes rescissionA3 weakSubstance 12/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment documents the commenter's personal and professional standing in Seattle and the Pacific Northwest, argues that the Draft EIS fails to identify specific fuel-reduction projects prevented by the 2001 Rule or account for long-term road maintenance and transition costs, cites data on road mileage, maintenance backlogs, and public opposition to support the claim that rescission is unnecessary and procedurally deficient, and requests the withdrawal of the proposal in favor of the No Action alternative.

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 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.
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.
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.
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
- “hiking, camping and paddleboarding in and around our national forests”
- “personally experienced the value that these undeveloped spaces provide to outdoor recreation enthusiasts”
- “outdoor recreation economy generates $730 billion annually, far more than timber sales”
Water Quality Quantity
- “sediment in streams”
- “downstream water quality impacts”
- “More than 60 million Americans depend on these watersheds for drinking water”
Governance Policy Process
- “Durable, predictable rules have value”
- “Replacing it with forest-by-forest decisions would mean decades of plan amendments, litigation and uncertainty”
- “The public has already spoken, and the process has been too short”
Forest Management Wildfire
- “The rule already allows the forest-health work the Department says it needs”
- “permits cutting small-diameter timber to reduce wildfire risk”
- “New roads add risk and cost rather than reducing them”

The comment

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

I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and to urge the Department to withdraw the proposal and select the No Action alternative in the Draft Environmental Impact Statement. I live in Seattle and spend much of my free time hiking, camping and paddleboarding in and around our national forests. I have hiked on the Pacific Crest Trail in California, Oregon, and Washington, and have personally experienced the value that these undeveloped spaces provide to outdoor recreation enthusiasts. I also work professionally in land use planning, and I would like to comment from both perspectives. 1. The rule already allows the forest-health work the Department says it needs. The proposal frames the rule as a barrier to forest management. But the 2001 rule already permits cutting small-diameter timber to reduce wildfire risk and improve habitat. It also allows road construction for public health and safety and for reserved rights. The DEIS should identify specific fuel-reduction projects that the rule actually prevented. If those cases are rare, a full rescission is far broader than the problem it claims to solve. 2. New roads add risk and cost rather than reducing them. Roads are a major source of human-caused ignitions, sediment in streams, and invasive species. The Forest Service already has 370,000 miles of forest roads with a multibillion-dollar maintenance backlog on its existing road system. Diminishing protections for nearly 45 million acres would add to a liability the agency cannot fund today. The cost-benefit analysis should fully account for long-term road maintenance and decommissioning costs, along with downstream water quality impacts. More than 60 million Americans depend on these watersheds for drinking water. In addition, the roadless areas offer abundant outdoor recreation opportunities such as hiking, hunting, fishing, camping, and other activities. Combined, the outdoor recreation economy generates $730 billion annually, far more than timber sales. 3. Durable, predictable rules have value. In land use, a stable framework that everyone understands is worth a great deal. That predictability helps communities, recreation businesses, Tribes, and local governments plan. For 25 years, the Roadless Rule has given that certainty. Replacing it with forest-by-forest decisions would mean decades of plan amendments, litigation and uncertainty. The proposal does not account for these transition costs. 4. The public has already spoken, and the process has been too short. USDA's August 2025 Notice of Intent drew more than 600,000 comments, about 99% of them opposed to rescission. The current comment window is also far shorter than past rounds. Before the original rule was adopted, the agency held more than 400 public meetings across the country after issuing the proposed rule. During the 2005 rescission attempt, the comment period totaled 182 days. A decision affecting nearly a third of the National Forest System deserves a comparable process. I respectfully ask the Department to withdraw the proposed rule and retain the 2001 Roadless Area Conservation Rule.