Comment Analysis · Docket FS-2025-0001

FS-2025-0001-601588

Opposes rescissionA3 weakSubstance 9/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents the commenter's request to retain the Roadless Rule via Alternative 1, citing specific wildfire mortality statistics and the Forest Service's 2025 admission of estimation difficulties regarding the rule's repeal.

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

Water Quality Quantity
- “clean drinking water”
- “protection of clean water and air”
- “critical benefits to communities”
Wildlife Habitat
- “wildlife habitat”
- “protection from the many destructive impacts of overdevelopment”
- “access to unadultured nature”
Recreation Tourism Public Use
- “opportunities for outdoor recreation”
- “places for people to hike, hunt, fish, camp, ski”
- “enjoy the outdoors”
Forest Management Wildfire
- “increases the risk of wildfires”
- “destroy an average of 7 million acres”
- “protection of life and the well-being of people”

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeAnalytical gapEvidenceRequestAlternative

The Forest Service should keep the Roadless Rule intact exactly as it is, utilizing Alternative 1 in the current DEIS. I am deeply disappointed by the proposal to remove the Roadless Rule. The areas currently protected by this policy provide critical benefits to communities across the country, including clean drinking water, wildlife habitat, opportunities for outdoor recreation, and protection from the many destructive impacts of overdevelopment. Opening these lands up to logging and other development strongly increases the risk of wildfires, which already destroy an average of 7 million acres, thousands of structures, and an average of 20,000 people each year from SMOKE alone. This fails to take into account those who die directly from these fires. The Forest Service itself said in 2025 that it was difficult to estimate such effects of this rule being repealed. Our greed for more possessions and money should never be given priority over the protection of life and the well-being of people, which necessitates the protection of clean water and air and access to unadultured nature. These lands are an important part of the character and identity of many communities and provide places for people to hike, hunt, fish, camp, ski and otherwise enjoy the outdoors. The Roadless Rule has provided consistent, nationwide protections for these special places for decades. The Forest Service should not weaken those protections or open currently protected roadless lands to new development. I fervently request the Forest Service to pursue Alternative 1 and retain or preferably, strengthen the existing Roadless Rule protections.