Comment Analysis · Docket FS-2025-0001

FS-2025-0001-582771

Opposes rescissionA2 moderateSubstance 13/24Owed an answerPosted October 6, 2026 On Regulations.gov

Small family — One letter sent by 3 to 9 people, copied or lightly reworded. One of 4 submissions in its group; the sender added words of their own. See the letter, its submissions and topics.

In short: The comment documents that the DEIS's analysis of municipal water use (pp. 127-132) incorrectly states 'no effect' and contains an incomplete sentence at p. 131, while providing specific data on fire risk, water quality degradation, and economic impacts to support a request to rescind the proposal or implement specific protective alternatives.

Scored with own additions — A family member whose own text beyond the shared letter was scored and combined with the letter's score.

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, Alternative.

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

Tribal Sovereignty
- “violation of the Constitution, Federal law, treaty obligations, Tribal sovereignty”
- “government-to-government consultation with affected Tribes”
- “sacred sites and ancestral homelands”
- “treaty-reserved rights”
Environmental Protection Biodiversity
- “327 ESA-listed species and 71 critical habitats would be negatively impacted”
- “irrevocable devastation it would cause”
- “destroys habitat”
- “sustain ecosystems Tribal Nations have relied on for generations”
Forest Management Wildfire
- “could actually increase fire risk”
- “More roads will result in more human-caused fires in the backcountry”
- “Agencies already have authority to manage fuels and fight fires in roadless areas”
- “Livestock grazing spreads invasive grasses that exacerbate wildfires”
Water Quality Quantity
- “pollutes clean water”
- “drinking-water sources”

The comment

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

I urge you to rescind the proposal discussed in FS-2025-0001-223869, Special Areas: Roadless Area Conservation, because of the irrevocable devastation it would cause. Once roads are built, there is no way to undo the damage. According to the analysis in the DEIS, elimination of the Roadless Rule across 45 million acres nationwide would result in a loss of up to $9 million a year from lowered visitor spending, especially hurting local communities, 327 ESA-listed species and 71 critical habitats would be negatively impacted, threaten Tribal sacred and archeological sites, exacerbate the Forest Service’s estimated maintenance backlog of over $8.6 billion covering the existing 370,000 miles of roads, and could actually increase fire risk. More roads will result in more human-caused fires in the backcountry. Research shows that more than 60 percent of human-caused fires on national forests in the Lower 48 states are ignited within 1/8-mile of the nearest road, and 95 percent are ignited within 1/2-mile. Agencies already have authority to manage fuels and fight fires in roadless areas, including the construction of roads for emergency situations. There is no reason to repeal the Roadless Rule. One of the principal reasons the Roadless Rule was adopted was its important role protecting clean water. Roadless areas provide high water quality for downstream communities and farms. US National Forests are one of the largest sources of municipal water supply in the nation, serving over 60 million people in 3,400 communities in 33 states. Most Wild and Scenic Rivers in California flow into water supply reservoirs that contribute critical water supplies to the fourth largest economy in the world. Roads and the resource extraction projects roads facilitate (logging, mining, etc.) are a primary source of erosion and sedimentation on our national forests. Roads threaten high-quality streams and rivers. Dirt and sediment that runs off roads impairs water quality, and roads in steep, rugged country increase the risk of landslides that smother streams and rivers with mounds of mud. USDA's own draft environmental impact statement found that landslides are six to nine times more likely next to forest roads. There is already a shortage of drinking water. Enacting this proposal will make that shortage even more severe because of water contamination. Communities depend on clean water for drinking, irrigation, and business processes. Increased water contamination will raise costs for local water treatment and inflate families’ water bills at a time when many are already struggling with high costs of living as well as harm their health. The DEIS analyzes municipal water use at pp. 127-132 of Volume I, and that analysis states no effect under any alternative. I request that the FEIS: 1. Correct the incomplete sentence at p. 131 and state, for each alternative, the agency's finding on effects to municipal water use - expressed in the units the DEIS's own tables already use, intakes and population served by region. 2. Carry the sediment-delivery mechanism stated at p. 130 through to municipal source water, including effects on treatment cost and on treatment capacity during storm and post-disturbance runoff. 3. Disclose, for each region where the record identifies a specific system, what that analysis shows for the systems identified, using the Salt Lake City supply documented at Vol. III, pp. 246-247 as the worked example. Given the widespread multifaceted harms repealing the Roadless Rule would cause it is imperative that it be improved by: Eliminating the logging loopholes. Logging does not improve anything - it only causes degradation. Instead of the 2000 EIS estimated ~ 1,400 acres of logging in roadless areas across the nation annually, on average from 2008-2018, there has been 3,200 acres of inventoried roadless logging annually in Montana alone. The majority of which was from using Roadless Rule loopholes. Eliminating livestock grazing in our inventoried roadless areas. Livestock grazing spreads invasive grasses that exacerbate wildfires, displaces wildlife, destroys habitat, and pollutes clean water. Despite being only four percent of livestock production in this nation, livestock grazing is pervasive on nearly 250 million acres of our public lands. The Forest Service is clandestinely restocking vacant grazing allotments with cattle, including in roadless areas and Wilderness, without public knowledge or participation. Restricting motorized and mechanized use in our inventoried roadless areas. Research shows that motorized and mechanized access (on roads, trails, or over the snow) harm wildlife, from elk to grizzly bears. Extend the provisions of this strengthened national rule to Idaho and Colorado, which currently have less protective rules. Thank you