Comment Analysis · Docket FS-2025-0001

FS-2025-0001-599964

Opposes rescissionA2 moderateSubstance 10/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment establishes that the agency's DEIS failed to substantively respond to over 220,000 prior comments, withheld the final Tribal Impact Summary Statement from public comment, eliminated protective alternatives based on deregulatory executive orders rather than NEPA requirements, and failed to assess reliance interests despite soliciting them, while citing agency data showing water impacts on 2,264,400 people.

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, 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.
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.

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.
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

Water Quality Quantity
- “Water from national forest country in the Pacific Southwest Region reaches as many as 2,264,400 people downstream”
- “My tap may be one of them”
- “reliance interests in the current rule”
Tribal Sovereignty
- “Tribal consultation is incomplete”
- “threat to inherent rights, Tribal sovereignty, cultural survival”
- “complete all 64 requested consultations”
- “Traditional Homelands Conservation Rule”
Governance Policy Process
- “Counting comments is not responding to them”
- “purpose written as deregulation forecloses the comparison NEPA requires”
- “analyse at least one protective alternative in full”
- “agency changing course must assess the reliance interests”
Environmental Protection Biodiversity
- “back off taking from the earth for awhile”
- “ecological health of ancestral homelands”
- “retain the 2001 rule's protections”

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 We are already seeing what happens when we use too many resources. Let's back off taking from the earth for awhile. Water from national forest country in the Pacific Southwest Region reaches as many as 2,264,400 people downstream, by the agency's own data. My tap may be one of them. I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule. I raise the following issues for the record and ask that the agency respond to each of them: Issue 1: The substance of round one is never answered I commented in the first round, and I have read what the agency says it did with everything we sent. Its own account describes counting, not answering: By the agency's own count, over 220,000 comment letters were received, representing over 625,000 submissions, and approximately 99 percent were generally opposed to the rescission. The DEIS says the comments helped inform the alternatives and identifies no issue that changed anything. Counting comments is not responding to them. I ask that the agency state which substantive issues from the first comment period altered the proposal, and which were rejected and why. Issue 2: Tribal consultation is incomplete and its summary is withheld from comment I commented in the first round and waited to be heard. By the agency's own record, others owed a far more formal hearing are still waiting too: The Forest Service received 64 requests for Tribal consultation; 29 consultations have been held and 5 more scheduled, with the published Tribal Summary Impact Statement records that the majority sentiment among consulted Tribal governments is opposition, viewing the rescission as a threat to inherent rights, Tribal sovereignty, cultural survival and the ecological health of ancestral homelands; the final Tribal Impact Summary Statement is deferred to the final rule. Tribal governments proposed alternatives, including a strengthened roadless rule and a Traditional Homelands Conservation Rule, and none was analysed; the final impact statement arrives only when comment is closed. I ask that the agency complete all 64 requested consultations and publish the Tribal Impact Summary Statement for public comment before any final rule. Issue 3: Every conservation alternative was eliminated by how the purpose was written I took the time to comment before, and I expected the alternatives to reflect what the public asked for. The agency's own document shows how it wrote every protective option out of consideration: Alternatives with more protection were dismissed as not responsive to the deregulatory executive orders, and the keep-boundaries option was cut because it "would continue to restrict local decision-making discretion" and because analysing roadless values is "an administrative and legal burden for the agency." A purpose written as deregulation forecloses the comparison NEPA requires. I ask that the agency restate the purpose and need in terms of forest conditions and analyse at least one protective alternative in full. Issue 4: Reliance interests are invited and never assessed How this reaches me is stated above in my own words, and that is a reliance interest. The agency asked for exactly this and then weighed none of it: The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. Under Encino Motorcars and Regents, an agency changing course must assess the reliance interests its prior policy created. This comment is such an interest. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one. I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule's protections. Where this proposal rests on factual conclusions that differ from the agency's own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record. Sincerely, Brenna Geehan San Francisco, CA