Comment Analysis · Docket FS-2025-0001

FS-2025-0001-590391

Opposes rescissionA1 strongSubstance 10/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment documents that the commenter, a resident of Scottsdale, Arizona and user of the Kaibab National Forest and Grand Canyon, argues the proposal's analysis fails to justify rescinding the 2001 Roadless Rule due to modest benefits, unanalyzed long-term impacts, and significant negative effects on recreation, water quality, and tribal interests, urging the adoption of the No Action alternative.

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 Analytical gap, 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.
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.
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.
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.

Topics

Recreation Tourism Public Use
- “off-trail backpacker”
- “value comes from the absence of roads”
- “quiet, remote and self-reliant recreation”
- “recreationists could lose about $6.1 million each year”
Governance Policy Process
- “Forest plans are not an equivalent safeguard”
- “no national floor”
- “undermines the legitimacy of this process”
- “administrative problem the agency can fix with guidance”
Water Quality Quantity
- “degrades watersheds”
- “sends sediment into streams and drinking water sources”
- “water quality”
Tribal Sovereignty
- “most consulted Tribal governments oppose it”
- “citing sacred sites”
- “subsistence resources”

What it names

National Forests: Kaibab National Forest
Law cited: 36 CFR 294

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeAnalytical gapEvidenceRequestAlternativeLegal

I live in Scottsdale, Arizona. I urge the Department to withdraw this proposal, adopt the No Action alternative, and retain 36 CFR 294 Subpart B in full. I spend a large part of my life in places this rule protects. I'm an off-trail backpacker who has spent more than a month below the Grand Canyon's rim, often starting from the Kaibab National Forest. I'm also a mountain biker, bikepacker, and former professional bike mechanic involved in Arizona cycling events. To me and to the communities around these lands, their value comes from the absence of roads. 1. The proposal's own analysis does not support its stated need. The Summary of Potential Impacts says management opportunities "would be modest and localized." It also says broad timber harvest gains are unlikely because of budgets, operability, and markets. A modest, uncertain benefit does not justify removing a protection that has worked for 25 years. The existing rule already allows small-diameter timber cutting to reduce the risk of uncharacteristic wildfire (§294.13(b)(1)). It also allows roads when there is an imminent threat of fire or flood (§294.12(b)(1)). The proposal's complaint is that these exceptions have been applied in a "limited and inconsistent" way. That is an administrative problem the agency can fix with guidance, not a reason to repeal the rule. 2. Roads add fire risk, and the agency cannot maintain the roads it already has. The proposal acknowledges that greater access can increase human-caused ignitions. It also acknowledges a $6.9 billion deferred maintenance backlog for roads and bridges. Adding miles to an unfunded road system degrades watersheds and sends sediment into streams and drinking water sources, which the agency itself names as conservation priorities. 3. The economics favor keeping the rule. The analysis estimates recreationists could lose about $6.1 million each year. The offsetting timber revenue of $5.2–11.4 million is a figure the agency itself says is unlikely to be fully realized. Recreation value recurs every year, while harvest revenue is speculative. The proposal also concedes tradeoffs with "quiet, remote and self-reliant recreation," which is scarce and cannot be replaced. Once a roadless area is roaded, it cannot be restored on any practical timeline. 4. Forest plans are not an equivalent safeguard. The proposal says rescission does not require any plan amendments. It also says local officials could later amend or revise plans to allow more roads and harvest, and that those changes fall outside this analysis. So the real impacts of rescission have not been analyzed. Protection for tens of millions of acres would come to depend on separate decisions, forest by forest, with no national floor. A consistent national standard is what makes these protections durable. 5. The public and Tribes have already weighed in. The overwhelming majority of comments on the notice of intent opposed rescission. The proposal itself reports that most consulted Tribal governments oppose it, citing sacred sites, subsistence resources, and water quality. Going ahead despite that record undermines the legitimacy of this process. 6. Reliance interests. The Department asked about reliance interests. For a quarter century, outfitters, guides, event organizers, and residents have planned their livelihoods and recreation around intact backcountry. [Optional: add a specific place you use or an event you support.] I ask the Department to select the No Action alternative and keep the 2001 Roadless Rule in place. Sincerely, Gerrit