Comment Analysis · Docket FS-2025-0001

FS-2025-0001-581728

Opposes rescissionA1 strongSubstance 5/24Owed an answerPosted October 6, 2026 On Regulations.gov

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

A1 strong: Must be answered — it names the law.

Owed an answer on Legal.

Standard dismissals it defeats

  • 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.
  • 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.

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.
  • 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.
  • Outside the scope The agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.

Topics

  • Environmental Protection Biodiversity
    • “habitat for fish and wildlife (including at-risk species)”
    • “last large, intact forest landscapes”
    • “protects irreplaceable public resources”
  • Water Quality Quantity
    • “provide clean drinking water for downstream communities”
    • “increase erosion and sedimentation in streams”
  • Public Opinion Support
    • “ignores overwhelming public support”
    • “2025 scoping period on this rescission drew more than 220,000 comment letters, overwhelmingly opposed”
    • “Reversing a long-standing national policy against such clear public sentiment is not a sound basis for rulemaking”
  • Forest Management Wildfire
    • “The Rule does not prevent wildfire management”
    • “allows the cutting of generally small-diameter timber to reduce the risk of uncharacteristic wildfire”
    • “Road construction tends to increase human-caused ignitions”

What it names

Law cited
36 CFR part 294

The comment

I write to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (36 CFR part 294, subpart B) and urge the Department to withdraw the proposal and keep the Rule in place. The Rule protects irreplaceable public resources. For 25 years, the Roadless Rule has protected roughly 45 million acres of national forest land, outside the separate Idaho and Colorado rules, from new road construction and most commercial logging. These are some of the last large, intact forest landscapes in the country. They provide clean drinking water for downstream communities, habitat for fish and wildlife (including at-risk species), and hunting, fishing, hiking and other recreation that supports rural economies. Once roads are built, these values are effectively lost for good. The Rule does not prevent wildfire management. The 2001 Rule already allows the cutting of generally small-diameter timber to reduce the risk of uncharacteristic wildfire. It also allows roads where needed to protect public health and safety from catastrophic events. Road construction tends to increase human-caused ignitions. Rescinding the Rule is not necessary for responsible fuels work, and the Department has not shown that it would improve fire outcomes. The Forest Service cannot maintain the roads it already has. The agency already carries a large backlog of deferred road maintenance. Adding new roads in remote terrain would worsen that burden, increase erosion and sedimentation in streams, and divert limited funds from existing infrastructure the public relies on. The proposal ignores overwhelming public support. The original Rule drew more than 1.6 million comments, the vast majority in favor. The 2025 scoping period on this rescission drew more than 220,000 comment letters, overwhelmingly opposed. Reversing a long-standing national policy against such clear public sentiment is not a sound basis for rulemaking. The Department has not provided an adequate justification. An agency that changes course must acknowledge the change, give good reasons for it, and account for the serious reliance interests the prior policy created. Communities, tribes, outfitters, and state and local governments have relied on these protections for a quarter century. A general goal of "reducing regulatory burden" does not explain why case-by-case forest planning would better protect these areas. The shortened comment period on a rule of this scale and its Draft EIS has also limited meaningful public participation.

Keep learning. Keep speaking up.The Roadless Rule depends on public engagement. Share what you've learned.

© 2026 roadless.org - Defending America's Last Wild Forests

Privacy Policy|Questions or concerns? noroads@roadless.org|Follow us: @defendroadless