Comment Analysis · Docket FS-2025-0001

FS-2025-0001-595485

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.

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

Wildlife Habitat
- “irreplaceably provide important habitat for 57% of vulnerable terrestrial wildlife”
- “fragment habitat areas”
- “The importance of U.S. national forest roadless areas for vulnerable wildlife species”
Recreation Tourism Public Use
- “currently intact wild lands are popular for recreation”
- “irretrievably impact the scenery and self-renewal offered by hiking, hunting, birdwatching, backpacking”
- “enjoying intact woods”
Economic Impact Fiscal
- “Roadless Area Conservation Rule brings $24 billion in benefits annually”
- “significant socio-economic loss in “non-commodity values””
- “Roads are a costly expense”
Water Quality Quantity
- “diminish water quality”
- “Roadless areas help protect against human-cause wildfires”

What it names

Works cited: 10.1016/j.gecco.2021.e01943

The comment

I strongly oppose rescinding the Roadless Rule and urge adopting Alternative 1 (no action). The currently intact wild lands are popular for recreation. Making up just 2 percent of the land in the lower 48 states, they irreplaceably provide important habitat for 57% of vulnerable terrestrial wildlife. Roadless areas help protect against human-cause wildfires — that’s because wildfires are four times more likely near roads, according to the DEIS. It states that “ignition density is approximately four times greater on other NFS lands compared to potentially affected IRAs and wilderness.” One reason the Roadless Rule was implemented in the first place was the Forest Service doesn’t have the money to maintain the roads it currently has. Roads are a costly expense. They also diminish water quality, fragment habitat areas, and irretrievably impact the scenery and self-renewal offered by hiking, hunting, birdwatching, backpacking and otherwise enjoying intact woods. The DEIS acknowledges the significant socio-economic loss in “non-commodity values” if the rule is rescinded. An economic analysis by Earth Economics found that the Roadless Area Conservation Rule brings $24 billion in benefits annually. I join the chorus of fellow citizens calling for abandoning the proposed rescission of the Roadless Rule. Select “No Action” on the DEIS. Sources: Dietz, M. S., et al. “The importance of U.S. national forest roadless areas for vulnerable wildlife species.” Global Ecology and Conservation, vol 32, e01943, 2021, doi.org/10.1016/j.gecco.2021.e01943. https://www.sciencedirect.com/science/article/pii/S2351989421004935?via%3Dihub Delaney, G. “Roadless Area Conservation Rule Brings $24B in Benefits.” Earth Economics, https://www.eartheconomics.org/news/roadless-rules.