Comment Analysis · Docket FS-2025-0001

FS-2025-0001-583539

Opposes rescissionA0 noneSubstance 6/24Posted 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

A0 none: Counted, not answered.

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

  • Environmental Protection Biodiversity
    • “destroying what remains of un-carved wildlife habitat”
    • “Roadless forests represent some of the most intact, resilient ecosystems”
    • “fragment wildlife habitat”
    • “severe consequences for wildlife, biodiversity”
  • Water Quality Quantity
    • “leaching sediment and pollutants into vital watersheds”
    • “degrades water quality”
    • “filter and store clean water”
    • “clean water sources”
  • Climate Carbon Storage
    • “reducing the carbon-storing effect of our forestland”
    • “increasing climate changes”
    • “erode the very ecological resilience we need in the face of a warming climate”
    • “climate resilience”
  • Governance Policy Process
    • “abridged and inadequate public comment process”
    • “rushed process that limits and ignores input”
    • “undemocratic and deeply irresponsible”
    • “Select the NO Action Alternative”

What it names

National Forests
Tongass National ForestWillamette National Forest

The comment

We already have plenty lands devoted to timber-production, riddled with roads, many not properly maintained, and continuously leaching sediment and pollutants into vital watersheds and fisheries. Let’s not allow such short-sighted plans to liquidate these remaining wild road-less places in the guise of ‘sustainable’ jobs or wood supplies. Nor buy-into the unsupported claims that more roads will help reduce wildfires. Select the NO Action Alternative: Retain the Roadless Conservation Rule of 2001, with no exceptions. We really shot ourselves in the foot during the rampant unsustainable levels of timber harvest in the past decades- in the 1970s and 1980s -we were shipping every 5th old log overseas. Foreign countries got ‘sweet heart deals’ liquidating the Tongass National Forest, or Olympic, Deschutes, Umpqua, Gifford-Pinchot, Colville or Willamette National Forest, to name a few, just in this region of the U.S. We need to keep this late-landing, sensible conservation measure of the Roadless Conservation Rule 2001, in place now more than ever, with the increasing climate changes. Roads in the Roadless Areas are a long-term cost we simply cannot afford. In terms of destroying what remains of un-carved wildlife habitat, reducing the carbon-storing effect of our forestland, the cost is just too big. Decades of studies have shown that road-building introduces invasive plants and pests, reduces forest resilience, degrades water quality, destroys fisheries habitat, requires ongoing maintenance, and increases fire-risk. Beyond the economic folly, the environmental consequences are severe. Roadless forests represent some of the most intact, resilient ecosystems left in our country. They filter and store clean water, provide refuge for vulnerable species, and are some of the last remaining connectivity of wildlife corridors. Once roads and clearcuts fragment these landscapes, the damage is permanent. More roads in the backcountry also mean more fires: research shows wildfires are four times more likely to ignite near roads. Fighting those fires in remote areas is dangerous, costly, and diverts resources from protecting communities. Roads also spread invasive species, fragment wildlife habitat, and erode the very ecological resilience we need in the face of a warming climate. The Roadless Rule already includes exceptions for emergencies such as wildfire, and rescinding the Roadless Rule for the stated purpose is unnecessary and dangerous. Equally troubling is the USDA’s decision to pursue this rollback through an abridged and inadequate public comment process. The original Roadless Rule was created after the most extensive public engagement process in the history of federal rulemaking, with over 95% of commenters supporting strong protections. During 2025's comment period on the Notice of Intent, over 600,000 Americans submitted public comments, with over 99% of comments opposing the proposed rescission of the rule. Now, the agency is attempting to dismantle these protections through a rushed process that limits and ignores input from citizens, scientists, Tribes, and local communities. This is undemocratic and deeply irresponsible for decisions of such sweeping consequence. For more than two decades, the Roadless Rule has been a cornerstone of sound forest management, balancing ecological, economic, and cultural values. Weakening or repealing it would be a grave mistake. Both Alternatives 2 and 3 will have severe consequences for wildlife, biodiversity, clean water sources, climate resilience, cultural resources, local economies, outdoor recreation, and the health of our nation's wildest forests. I urge the USDA to abandon this misguided effort and instead strengthen its commitment to protecting America’s roadless forests. The agency must choose the No Action alternative and maintain full Roadless Rule protections for America's wild forests. Sincerely, Mrs. A Higinbotham OR

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