Comment Analysis · Docket FS-2025-0001

FS-2025-0001-579254

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

In short: The comment documents the commenter's opposition to rescinding the Roadless Area Conservation Rule, citing specific DEIS findings on species impacts, water quality, wildfire risk, and economic costs, while requesting the adoption of the No Action alternative and a more robust public comment process.

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

Environmental Protection Biodiversity
- “adversely affect 327 threatened and endangered species”
- “71 designated critical habitats”
- “irreplaceable living model as we work to preserve ecosystems”
- “Old-growth stands cannot be restored on any human timescale”
Water Quality Quantity
- “road construction is the largest source of sediment from timber harvest”
- “major cause of water-quality degradation”
Governance Policy Process
- “The process is also inadequate”
- “More than 99% of comments in the 2025 round opposed repeal”
- “agency's own Tribal consultation found that most Tribal governments consulted oppose rescission”
- “Decisions of this scale deserve a longer comment period”
Economic Impact Fiscal
- “The economics also don't add up”
- “adding to a maintenance backlog already above $6.9 billion”
- “reduce recreation spending in nearby communities by an estimated $9 million a year”

What it names

Roadless areas: Dark Divide

The comment

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

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. For the reasons below, I urge the agency to adopt Alternative 1, the No Action alternative. I live in rural West Marin, California. Ancient forests have been central to my life since childhood; camping and hiking among old trees has connected me to my mother, to her family, and through them to my ancestors. I'm writing about the Dark Divide Roadless Area in southwest Washington, which conservation groups describe as one of the largest remaining old-growth forests in that part of the state. Ancient forests are where I have most directly experienced the sacred. They are also a tangible example of how complex systems evolve over centuries, and how diverse species adapt and sustain one another. The delicate balance of interdependency found most fully in old-growth forests, achieved over long spans of time, is an irreplaceable living model as we work to preserve ecosystems across our planet, to overcome short-term thinking, and to foster a culture that is more cooperative and less extractive. Cutting roads into old growth is like cutting into a living body: it opens the way to logging and careless heavy use that can wound what took centuries to form. We have very little of this natural space left. Public forests belong to all of us, including places I may never walk through. Rescission would remove the national protection that keeps roads and logging out of areas like the Dark Divide. Old-growth stands cannot be restored on any human timescale. The DEIS itself concedes that rescission would "adversely affect" 327 threatened and endangered species and 71 designated critical habitats, and that road construction is the largest source of sediment from timber harvest, a major cause of water-quality degradation. It also acknowledges that road density raises the number and frequency of human-caused wildfire ignitions, which undercuts the claim that rescission serves wildfire safety. I ask the agency to explain how it would prevent these harms in the Dark Divide if the national rule is removed. The economics also don't add up. The DEIS says new roads could be built across 18.2 million acres, adding to a maintenance backlog already above $6.9 billion, while rescission would reduce recreation spending in nearby communities by an estimated $9 million a year. The process is also inadequate. More than 99% of comments in the 2025 round opposed repeal, and the agency's own Tribal consultation found that most Tribal governments consulted oppose rescission. Decisions of this scale deserve a longer comment period and a real response to what the public has said. I oppose the proposal to rescind or alter the Roadless Rule and support Alternative 1. Laura Trippi