Comment Analysis · Docket FS-2025-0001

FS-2025-0001-591698

Opposes rescissionA3 weakSubstance 12/24Owed an answerPosted October 6, 2026 On Regulations.gov

Small family — One letter sent by 3 to 9 people, copied or lightly reworded. This comment stands for 3 submissions in its group; the sender added words of their own. See the letter, its submissions and topics.

In short: The comment documents that the Draft Environmental Impact Statement (DEIS) for the rescission of the 2001 Roadless Rule contains specific analytical deficiencies regarding wildfire risk, economic externalities, and cumulative ecosystem impacts, and formally requests the agency to select the No Action Alternative.

Scored as the letter — The shared letter of a family, scored once for everyone who sent it.

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.

Owed an answer on Analytical gap, Evidence.

Standard dismissals it defeats

Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
Outside the scope The agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.

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.
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.
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

Recreation Tourism Public Use
- “avid hiker and outdoor enthusiast”
- “irreplaceable sanctuary from the noise and development”
- “vital necessity for mental and physical well-being”
- “outdoor recreation and tourism economies”
Environmental Protection Biodiversity
- “safeguard vital habitat for threatened wildlife”
- “fragmentation of continuous habitats”
- “ecological integrity”
- “intact ecosystems provide critical benefits”
Water Quality Quantity
- “secure clean drinking water for millions of Americans”
- “degradation of municipal watersheds”
- “stream sedimentation”
- “soil erosion”
Climate Carbon Storage
- “buffer against climate change by storing vast amounts of carbon”
- “carbon sequestration capacity”
- “storing vast amounts of carbon”

The comment

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

I am writing to express my strong opposition to the U.S. Department of Agriculture’s (USDA) and U.S. Forest Service’s proposal to fully rescind the 2001 Roadless Area Conservation Rule (Roadless Rule). I strongly urge the agency to select Alternative 1 (the No Action Alternative) to maintain critical protections for our remaining 45 million acres of undeveloped National Forest System lands. As an avid hiker and outdoor enthusiast who frequently explores our public lands, I urge the Forest Service to maintain the existing protections for our 45 million acres of inventoried roadless areas. The backcountry trails in our National Forests provide an irreplaceable sanctuary from the noise and development of modern life. For me, hiking through pristine, undeveloped backcountry is not just a recreational hobby; it is a vital necessity for mental and physical well-being. Knowing that I can step onto a trail and experience a landscape largely unchanged by industrial activity is a privilege unique to the American public lands system. Repealing the Roadless Rule to open these wild spaces to expensive road construction and industrial logging would permanently alter the landscapes that millions of hikers, backpackers, and families enjoy. Beyond recreation, these intact ecosystems provide critical benefits that cannot be easily restored once damaged. They secure clean drinking water for millions of Americans, safeguard vital habitat for threatened wildlife, and act as an essential buffer against climate change by storing vast amounts of carbon. The Forest Service already struggles to manage an expansive existing road system that stretches hundreds of thousands of miles. Prioritizing the construction of new roads for corporate exploitation at the expense of ecological integrity and public recreation is a step backward. . The Draft Environmental Impact Statement (DEIS) fails to provide a rational, science-based justification for a full repeal. The agency's analysis contains severe deficiencies that must be addressed before any final decision is made: 1.Flawed Wildfire Risk Analysis The DEIS frames the full rescission of the Roadless Rule as a necessary measure for wildfire protection. This rationale fundamentally contradicts established fire ecology and the agency's own historical data. National Forest Service data demonstrates that approximately 90% of wildfires start within one-half mile of a road, largely driven by human activity. Constructing new roads into pristine backcountry forests will inherently increase human access and significantly elevate the baseline risk of fire ignitions. Furthermore, the USDA's own DEIS findings indicate that repealing the rule delivers little to no wildfire risk reduction. The final EIS must reconcile how expanding road infrastructure aligns with a stated goal of reducing wildfire prevalence. 2.Arbitrary Restrictions on Active Management The justification that the 2001 Roadless Rule acts as an absolute barrier to necessary ecological restoration and active management is inaccurate. The current rule already includes flexible, limited exceptions allowing for targeted timber harvesting and fuel reductions to protect communities and restore forest health. The agency has failed to demonstrate why a complete, sweeping rescission—which opens pristine habitats to commercial logging and permanent industrial road building—is a proportionate or necessary tool compared to utilizing existing rule mechanisms. 3.Inadequate Assessment of Local Economic Damage and Deficit Spending The DEIS fails to fully account for the severe economic externalities of a repeal. The agency currently faces a massive road maintenance backlog. Forcing the federal government to assume the long-term maintenance costs of new logging roads is a fiscally irresponsible use of taxpayer funds. Concurrently, the DEIS undervalues the robust, self-sustaining outdoor recreation and tourism economies that rely explicitly on backcountry, roadless characteristics. 4.Failure to Quantify Cumulative Impacts on Ecosystem Services The DEIS lacks a rigorous cumulative impacts analysis regarding the degradation of municipal watersheds, carbon sequestration capacity, and critical wildlife corridors. Road building is a primary driver of soil erosion, stream sedimentation, and the fragmentation of continuous habitats required by threatened and endangered species. For these reasons, the proposal to eliminate the Roadless Rule is arbitrary, capricious, and environmentally damaging. I request that the Forest Service abandon the proposed rescission and uphold the durable protections of the 2001 Roadless Rule. I strongly support the "No Action Alternative" to leave the 2001 Roadless Rule fully intact. Please protect our nation’s last remaining wild forests for current and future generations of hikers, campers, and outdoor stewards. Thank you for your time and for considering my comments.