Comment Analysis · Docket FS-2025-0001

FS-2025-0001-594827

Opposes rescissionA2 moderateSubstance 8/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment documents that the agency's claim that the 2001 Rule limits vegetation management is unsupported by the Rule's text, which permits fuel reduction and emergency road construction, and requests the retention of the 2001 Rule to protect water quality, wildlife habitat, and reduce wildfire risk.

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

A2 moderate: Hard to dismiss — it shows cause and effect.

Owed an answer on Analytical gap.

Standard dismissals it defeats

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.

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.
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

Wildlife Habitat
- “photographed the Elegant Trogon and Montezuma Quail”
- “Species like these depend on large, intact, unfragmented habitat”
- “Roads and the traffic and disturbance they bring are among the most significant threats to birds”
- “Loss of habitat and ecosystem resilience”
Water Quality Quantity
- “Threats to clean drinking water”
- “Roads are one of the leading sources of sediment pollution in forest streams”
- “Protecting roadless headwaters is one of the most cost-effective ways to protect water supplies”
- “filter water from lakes and rivers to drink”
Forest Management Wildfire
- “The Rule already allows the cutting of generally small-diameter timber to reduce the risk of uncharacteristic wildfire”
- “new roads bring people and vehicles closer to dry vegetation and increase human-caused ignitions”
- “fires are 4x more likely to start near a road than in a roadless forest”
- “Rescinding the Rule would not meaningfully improve the Forest Service's ability to fight fire”
Recreation Tourism Public Use
- “I am also an amateur bird photographer and avid hiker”
- “These are places where we camp, hike, fish, kayak”
- “impact a number of public lands where I, and so many others, frequently recreate”
- “quiet, remote, and backcountry recreation values”

What it names

National Forests: Coronado National Forest Inyo National Forest

Attachments

1 file. Counts as 1 — Counts as one: The attachments enclose no one else's submissions; the comment counts as one.

Own letter

The comment

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

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule, and I urge the Forest Service to reject both the full rescission and the partial modification alternative and retain the 2001 Rule in its entirety. I live in two states, spending different parts of the year in California and Arizona. I have a background in Environmental Science and work in corporate sustainability. I am also an amateur bird photographer and avid hiker. Rescinding the Roadless Rule will impact a number of public lands where I, and so many others, frequently recreate: the Apache-Sitgreaves, Coconino, Coronado, Kaibab, Prescott, and Tonto National Forests in Arizona, and the Inyo, Lassen, Sierra, Sequoia, Tahoe, and Shasta-Trinity National Forests in California. These are places where we camp, hike, fish, kayak, and filter water from lakes and rivers to drink. They are also where I see and photograph native and migratory birds. In the Coronado National Forest, I have photographed the Elegant Trogon and Montezuma Quail. In the Inyo National Forest, I have photographed the Greater Sage-Grouse. Species like these depend on large, intact, unfragmented habitat, which is exactly what roadless areas provide. Roads and the traffic and disturbance they bring are among the most significant threats to birds like these. Rescinding the rule removes protections for 45 million acres of the wildest and most intact public lands. The total land mass of the United States is approximately 2.2 billion acres, so 45 million acres represents only 2% of it. We do not need to open these areas to road construction, development, and commercial logging when so many other lands already support these activities. Opening these areas will harm the public and our ecosystems in the following ways: 1. Increased wildfire risk. The Department argues that the 2001 Rule has limited vegetation management and contributed to a lack of active management. That is not supported by the Rule itself. The Rule already allows the cutting of generally small-diameter timber to reduce the risk of uncharacteristic wildfire. It also allows road construction when needed to protect public health and safety from an imminent threat of fire, flood, or other catastrophic event. The fuel reduction work that most protects homes and communities is concentrated in the wildland-urban interface, not in remote backcountry far from any town. Meanwhile, new roads bring people and vehicles closer to dry vegetation and increase human-caused ignitions. Studies show that fires are 4x more likely to start near a road than in a roadless forest. Rescinding the Rule would not meaningfully improve the Forest Service's ability to fight fire. It would add new ignition sources to some of our most remote and hardest-to-reach forests. 2. Threats to clean drinking water. National forests are a major source of drinking water across the West, and roadless areas sit in many of the headwaters that feed the rivers and reservoirs our communities depend on. Roads are one of the leading sources of sediment pollution in forest streams. They erode, channel runoff, and deliver silt and contaminants directly into waterways. That degrades water quality for downstream communities and increases treatment costs for municipal water systems. It also affects people like me who filter water directly from backcountry lakes and streams. Protecting roadless headwaters is one of the most cost-effective ways to protect water supplies for tens of millions of people. 3. Loss of habitat and ecosystem resilience. Roads fragment habitat for sensitive species and degrade our most intact and resilient ecosystems. In my work in corporate sustainability, companies increasingly recognize the value of natural capital, including carbon storage, watershed protection, and biodiversity. These intact ecosystems deliver those benefits at no cost to taxpayers, and they represent only 2% of our land mass. They should be protected. 4. Increased taxpayer burden. The Forest Service already manages roughly 370,000 miles of roads and faces a multibillion-dollar deferred maintenance backlog. It lacks the staff and funding to maintain the roads it already has. Building more roads in roadless forests will only add to that backlog and shift more cost onto taxpayers. In addition to making taxpayers pay more, rescinding the Rule ignores the will of the American people. When the Clinton Administration first proposed the Roadless Rule in 2000, it received over 1.6 million public comments, more than any administrative proposal in U.S. 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% urging that the Roadless Rule be retained. For these reasons, I urge the Forest Service to select the no-action alternative and keep the 2001 Roadless Area Conservation Rule in place.