Comment Analysis · Docket FS-2025-0001

FS-2025-0001-587328

Opposes rescissionA3 weakSubstance 5/24Owed an answerPosted October 6, 2026 On Regulations.gov

Small family — One letter sent by 3 to 9 people, copied or lightly reworded. One of 5 submissions in its group. See the letter, its submissions and topics.

Carries the letter's score — A copy of a family's letter; it holds the score and answerability level of the letter it sent.

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. This rating is the one its shared letter earned.

Owed an answer on Evidence.

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
    • “Remove protections for 45 million acres of the wildest and most intact public lands”
    • “impair habitat for sensitive species and degrade our most intact and resilient ecosystems”
    • “create more degraded and fragmented habitat”
  • Water Quality Quantity
    • “threaten clean drinking water sources”
    • “safeguard watersheds that provide drinking water”
  • Tribal Sovereignty
    • “threaten Indigenous cultural values and sources of traditional foods, fiber, and medicines”
    • “majority sentiment among Tribal governments consulted is opposition to the proposed rescission”
  • Public Opinion Support
    • “Ignore the will of the American public”
    • “over 99% of comments urging that the Roadless Rule be preserved”

The comment

I am writing to oppose the repeal of the Roadless Rule. Eliminating the Roadless Rule would: • Threaten Indigenous cultural values and sources of traditional foods, fiber, and medicines. • Increase taxpayer burden. The existing National Forest road system already has a $6.9 billion deferred maintenance backlog according to the draft EIS. The Forest Service already lacks enough staff and funds to maintain existing roads.

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