Comment Analysis · Docket FS-2025-0001

FS-2025-0001-591438

Opposes rescissionA0 noneSubstance 1/24Posted October 6, 2026 On Regulations.gov

Small family — One letter sent by 3 to 9 people, copied or lightly reworded. One of 3 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

A0 none: Counted, not answered. This rating is the one its shared letter earned.

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

Forest Management Wildfire
- “most fires start near roads”
- “focus on thinning and restoring forests along areas with current roads”
- “decommissioning less used routes for fire safety”
- “human caused fires along new roads”
Economic Impact Fiscal
- “unfunded maintenance burden”
- “dubious that such proposed new roads and harvests will pencil out”
- “Funds for road maintenance were so short”
Environmental Protection Biodiversity
- “permanently harming local soils”
- “steep, prone to landslides”
- “difficult to harvest without permanently harming local soils”

The comment

Thank you for the opportunity to comment on this proposed policy change. As a person familiar with western public lands, having worked both for the U.S. Forest Service, and local non-profits, I have listened to much debate regarding the roadless rule since its enactment in 2001. I understand the concerns expressed by the current proposed change regarding access for firefighters, timber harvest, and other legitimate Forest uses. However, on balance, my experience and my research leads me to believe that the 2001 roadless rule should remain in place. In much of the lower 48 states, the areas that currently lack roads are steep, prone to landslides, and are difficult to harvest without permanently harming local soils (which are fundamental to the ability of our lands to grow trees) and/or the roads themselves. It is dubious that such proposed new roads and harvests will pencil out. Funds for road maintenance were so short during my time with the U.S. Forest service that travel was very slow and we avoided USFS roads where alternatives were available. Adding additional roads to public lands will not help, but simply add to the unfunded maintenance burden. Furthermore, roads also provide access to the public and, as public firefighters have repeatedly stated, most fires start near roads, often because a member of the public is not following proper procedures. This forces the USFS to expend precious resources patrolling the woods. In my experience, the public is also extremely adept at getting through locked gates and other barriers. The USFS and private contractors are already adept at accessing remote sites without roads. We don't need to provide more opportunities for human caused fires along new roads in our forests, especially given how much the land management agency budgets are currently being eaten up by fire suppression efforts. We should instead focus on thinning and restoring forests along areas with current roads and decommissioning less used routes for fire safety. Respectfully, Robert Hladky 88001 9th St. Veneta, OR 97487 (541) 223-9862