Comment Analysis · Docket FS-2025-0001

FS-2025-0001-599976

Opposes rescissionA3 weakSubstance 5/24Owed an answerPosted October 7, 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 Analytical gap.

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

Economic Impact Fiscal
- “fiscal discipline”
- “$6.9 billion backlog in road and bridge maintenance”
- “economic return does not justify the cost”
- “add costs for taxpayers”
Forest Management Wildfire
- “active wildfire management”
- “fuel treatments in roadless areas have been carried out at a higher rate”
- “wildfire ignitions are least dense in roadless and wilderness areas”
- “increase funding to the Forest Service”
Recreation Tourism Public Use
- “hunting and fishing heritage”
- “best big-game habitat left in the country”
- “steady revenue to gateway towns”
- “pristine, undisturbed areas”
Water Quality Quantity
- “Clean water for local communities”
- “protect the headwaters of 354 municipal watersheds”
- “intact forest is the cheapest water treatment available”
- “local ratepayers will face treatment costs”

The comment

Re: Docket FS-2025-0001 — Proposed Rescission of the 2001 Roadless Area Conservation Rule I urge USDA to keep the 2001 Roadless Rule and make targeted improvements to it, rather than rescinding it. I support fiscal discipline, active wildfire management, and responsible use of public resources. A full rescission works against all three. It would add costs for taxpayers and take something valuable from sportsmen and rural communities. 1. Fiscal responsibility: The Forest Service already has an estimated $6.9 billion backlog in road and bridge maintenance. Every new mile of backcountry road becomes a permanent liability on the federal balance sheet. Taxpayers should not be asked to pay for new roads when the agency cannot maintain the ones it has. The agency's own analysis finds only about 4.8 million acres where timber operations would be both allowed and physically feasible. That is a small share of the roughly 45 million acres affected, so the economic return does not justify the cost. 2. The rule is not what's stopping wildfire work. The agency's own management records show that fuel treatments in roadless areas have been carried out at a higher rate per square kilometer than elsewhere in the National Forest System. Research covering three decades of data found that wildfire ignitions are least dense in roadless and wilderness areas. Areas within about 160 feet of a road see up to four times as many ignitions, mostly from human causes. Mitigation dollars do the most good near homes and communities, not in remote backcountry. If you want to address wildfire risk, increase funding to the Forest Service. 3. Hunting and fishing heritage: Roadless areas hold some of the best big-game habitat left in the country. About 58% of them overlap elk habitat, and about 70% hold native trout or salmon. The hunters and anglers who use these areas bring steady revenue to gateway towns across the West, and that revenue depends on secure, undisturbed habitat. Sportsmen's groups such as Backcountry Hunters & Anglers and Trout Unlimited have urged USDA to keep the rule. As an Idaho resident, hunting and fishing access are important to me personally, but also to ours state's economy in the form of tourism. People come here to see pristine, undisturbed areas and hunt game that require undisturbed habitat. 4. Clean water for local communities. Roadless areas protect the headwaters of 354 municipal watersheds. For many small towns, intact forest is the cheapest water treatment available. If that protection is lost, local ratepayers will face treatment costs they cannot easily absorb. And it will be mostly rural, low-resource communities that feel this most. 5. National forests are owned by all Americans: the hunter in Idaho, the angler in Ohio, and the rancher in Montana alike. Decisions about their most intact backcountry should not depend on whoever has the most influence in a given planning cycle or statehouse. The 2001 rule was adopted after more than 600 public meetings and 1.6 million public comments. It has given land users, businesses, and communities 25 years of predictable rules. Rescinding it would replace that certainty with forest-by-forest decisions that can change with every plan revision, and with years of costly litigation. I respectfully ask USDA to withdraw the proposed rescission. Instead, the agency could clarify and streamline the rule's existing exceptions for fuels reduction and wildfire response, and increase funding to the Forest Service to better manage and protect these lands. That would deliver the management flexibility the agency is seeking while keeping America's best remaining backcountry intact for the public that owns it.