Comment Analysis · Docket FS-2025-0001

FS-2025-0001-595163

Opposes rescissionA3 weakSubstance 5/24Owed an answerPosted October 6, 2026 On Regulations.gov

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

A3 weak: Substantive, but easier to set aside.

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

Forest Management Wildfire
- “Mature, intact (not bisected by roads) forests are complex and naturally more fire resistant”
- “second growth forests feature a tight, all-one-height canopy that does not promote ecological diversity”
- “roads... increase the incidence of fire, not reduce it”
- “USDA Forest Service should start by requiring proper management second growth forests through ecological thinning and controlled burns”
Environmental Protection Biodiversity
- “Intact, mature forests and lands provide food, shelter, and long-term survival for our wildlife and healthy, diverse ecosystems”
- “greater diversity of tree species with different ages, canopy heights, tree circumferences, and spacing”
- “species and ecological diversity, shade, and moisture retention creates natural firebreaks”
- “industrial logging regimes, which cannot replicate natural processes”
Economic Impact Fiscal
- “USDA U.S. Forest Service's current and $5.98B FY2025 road maintenance backlog”
- “The proposal to rescind the Roadless Rule just does not make fiscal, logical, or ecological sense”
- “it is the U.S. Government and the U.S. taxpayer that will need to step in and help those communities”
- “federal government helps local communities recover... via U.S. taxpayer dollars”
Climate Carbon Storage
- “They also capture more carbon via photosynthesis”
- “stabilize local climates by retaining moisture and absorbing heat better than second growth or industrially managed forests do”
- “retain moisture and slow the flow of rain within their complex roots systems”

The comment

Dear USDA: Please do not rescind the Roadless Rule. The reasons why it should be kept in place permanently include, but are not limited to: increased, maximum, and optimized forest health; Landslides occur after modern forestry techniques and cutting roads into forests will only increase the immense damage landslides create; and USDA U.S. Forest Service’s current and $5.98B FY2025 road maintenance backlog. Please do not rescind the Roadless Rule for these reasons below (and so many more): Increased, maximum, and optimized forest health: Mature, intact (not bisected by roads) forests are complex and naturally more fire resistant. Intact, mature forests and lands provide food, shelter, and long-term survival for our wildlife and healthy, diverse ecosystems that sustain us and our way of life. They also capture more carbon via photosynthesis and stabilize local climates by retaining moisture and absorbing heat better than second growth or industrially managed forests do. Intact, mature forests contain a greater diversity of tree species with different ages, canopy heights, tree circumferences, and spacing -- mature trees are naturally more fire resistant. Their branches are higher above the forest floor, and they retain moisture and slow the flow of rain within their complex roots systems, promoting still more water retention by the diverse understory trees and plants grow in mature, intact forests. Their species and ecological diversity, shade, and moisture retention creates natural firebreaks and fire-resistant individual trees that will regenerate the forest. In opposition, the younger, even-age, densely packed trees of second growth forests feature a tight, all-one-height canopy that does not promote ecological diversity along the forest floor. Instead, these low diversity second growth forests are a source of fine ladder fuels of drier twigs and branches, essentially kindling, that are quick to burn hot and violently, with fire spreading rapidly along their densely packed tracts of young, trees and drier soils and limited, drier understory plants. The intensity of these forest fires are not natural to mature and intact forests. Extreme fires are characteristic of previously logged, second growth forests. This is true of clear, strip, shelterwood, or seed tree cutting industrial logging regimes, which cannot replicate natural processes. The largest trees are logged and removed, leaving the fine ladder fuels behind on disrupted and drier soils, which is quicker to ignite and spread along roads into the tree canopy of these logged areas and second-growth forests, resulting in more frequent, more violent fires. And more danger to our local communities and fire fighters. Also, after hot, fast, catastrophic fires occur in previously logged, second growth forests and along new roads, it is the U.S. Government and the U.S. taxpayer that will need to step in and help those communities that the USDA Forest Service effectively harmed by easing access for, thereby promoting, industrial extraction of our publicly shared resources and creating unhealthy ecosystems with even more problems. The proposal to rescind the Roadless Rule just does not make fiscal, logical, or ecological sense; it’s just not sound. To manage the incidence of fires, the USDA Forest Service should start by requiring proper management second growth forests through ecological thinning and controlled burns in coordination with local and indigenous communities. USDA U.S. Forest Service’s $5.98B FY2025 road maintenance backlog: Why would the federal government allow / promote more roads in our public forests, which again, promotes the spread of wildfires, if the USFS doesn’t have the staffing or funds to maintain the roads it already has in its portfolio? The U.S. Forest Service is already over $5,980,000,000, that’s $5.98 Billion dollars, behind in deferred maintenance road projects as of FY2025. This astounding $5.98M figure does not even include roads for high clearance vehicles or basic custodial care of roads (source: Fiscal Year 2025, Quarter 1 Deferred Maintenance Needs https://www.fs.usda.gov/sites/default/files/fy25-q1-deferred-maint-report.pdf). This plus the USFS's current backlog does not support creating more roads to maintain, which are shown to increase the incidence of fire, not reduce it. Landslides occur after modern forestry techniques and cutting roads into forests will only increase the immense damage landslides create: Landslides are also most likely to occur on clearcut second growth mountainsides. The federal government helps local communities recover when such a horrific landslide event occurs (if one can even recover from the loss of life, community, and land) via U.S. taxpayer dollars, yet the conditions for a landslide were really due to the private logging industry which disrupted the stability of a once intact, mature forest and mountainside.