Comment Analysis · Docket FS-2025-0001

FS-2025-0001-590887

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 oppose fully or partially rescinding the roadless rule because it would: Remove protections for 45 million acres of the wildest and most intact public lands across our National Forests, allow road construction, development, and commercial logging in currently protected inventoried Roadless Areas; Increase fire risk in backcountry forests. The Roadless Rule helps protect areas that are fire resilient and less prone to wildfire ignitions. Studies show that fires are 4x more likely to start near a road than in a roadless forest, and logging can increase fire hazard; Allow increased logging and roads that threaten clean drinking water sources. The Roadless Rule helps safeguard watersheds that provide drinking water, impair habitat for sensitive species and degrade our most intact and resilient ecosystems. Roadless areas provide some of the last best habitat areas that are still developing under the natural processes and landscape patterns that wildlife evolved with. Opening roadless areas to logging and road-building will create more degraded and fragmented habitat that is already vastly over-abundant, threaten Indigenous cultural values and sources of traditional foods, fiber, and medicines. The draft EIS states that “the majority sentiment among Tribal governments consulted is opposition to the proposed rescission”; 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, and building more roads in forests will only increase that backlog; Ignore the will of the American public. When the Clinton Administration first proposed the Roadless Rule back in 2000, it received well over a million public comments supporting the rule, more than any administrative proposal in US history at the time. When the Trump Administration initially proposed rescinding the Roadless Rule last September, over 600,000 Americans submitted public comments, with over 99% of comments urging that the Roadless Rule be preserved.