Comment Analysis · Docket FS-2025-0001

FS-2025-0001-600129

Opposes rescissionA2 moderateSubstance 6/24Owed 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

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

Owed an answer on Analytical gap.

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
- “Clean water matters to me”
- “my kids deserve these vast beautiful lands”
Forest Management Wildfire
- “fire safety argument does not hold up”
- “no analysis isolates roads as the cause”
- “most new roads expected under rescission would be temporary timber spurs”
Environmental Protection Biodiversity
- “adversely affect 327 ESA-listed species”
- “71 critical habitats”
- “permanent road construction and old-growth removal”
Legal Regulatory Framework
- “cannot have it both ways on irreversible harm”
- “reconcile that contradiction directly”
- “explain, on the record, why rescinding nationwide protections serves the public better”

The comment

Clean water matters to me, my kids deserve these vast beautiful lands, and I want to know how my tax money is being spent before it goes to something like this. The agency's fire safety argument does not hold up under its own numbers. The document states, at the Fire Control section, that "With increased road access, initial attack success rates would be expected to increase." But no analysis isolates roads as the cause of any difference in outcomes. The document itself acknowledges that less-than-full suppression is used more often in roadless areas, which makes any direct comparison of initial attack success rates unreliable without controlling for suppression strategy. It also concedes that most new roads expected under rescission would be temporary timber spurs, not strategic fire roads. The agency needs to separate the effect of roads from suppression strategy in its initial attack comparison, and estimate how many fire-useful roads are actually expected given real funding limits. I want a clear answer to that specific question before this rule moves forward. The agency also cannot have it both ways on irreversible harm. The Scope of the Analysis section declares that "An irreversible or irretrievable commitment of resources will not be made by the rulemaking because none of the rulemaking alternatives propose specific actions," yet the same document discloses that rescission is likely to adversely affect 327 ESA-listed species and 71 critical habitats, and that permanent road construction and old-growth removal are reasonably foreseeable. Those are exactly the kinds of irreversible commitments the disclaimer purports to rule out. The Forest Service must reconcile that contradiction directly. This is a horrible priority when we need healthcare, affordable housing, food, and so many other essential services. Do you want kids to grow up without these vast beautiful lands? I don't. The agency should explain, on the record, why rescinding nationwide protections serves the public better than keeping them.