Comment Analysis · Docket FS-2025-0001

FS-2025-0001-601670

Opposes rescissionA3 weakSubstance 10/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents that the agency's wildfire rationale for rescinding the 2001 Roadless Rule is insufficient because 11.3 million acres are already near roads and only 5% of high-hazard acreage has been treated, while the proposal's true purpose appears to be opening areas like the Tongass National Forest to commercial extraction, which would increase erosion and sediment in drinking water sources.

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, 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

Environmental Protection Biodiversity
- “protects about 44 million acres of the last undeveloped land”
- “provide fish and wildlife habitat”
- “opening them to logging, and mining and energy development”
Water Quality Quantity
- “supply drinking water”
- “increase erosion and sediment in the streams that supply drinking water”
- “downstream communities”
Forest Management Wildfire
- “The wildfire rationale does not justify full rescission”
- “new roads can often raise fire risk”
- “address wildfire risk through the underused fuel treatments”
Recreation Tourism Public Use
- “hiked and camped in the National Forest System”
- “offer backcountry recreation”
- “understands what could be lost”

What it names

National Forests: Tongass National Forest

The comment

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

I am writing to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. I am someone who has hiked and camped in the National Forest System and understands what could be lost by implementing the proposal. As is, the rule protects about 44 million acres of the last undeveloped land in the National Forest System, which provide fish and wildlife habitat, supply drinking water, and offer backcountry recreation. Rescinding it would remove the only national protection these areas have, opening them to logging, and mining and energy development. The wildfire rationale does not justify full rescission. To begin with, new roads can often raise fire risk, since most wildfires are started by people. And the 2001 rule already allows cutting of small-diameter trees to reduce wildfire risk and permits road construction when needed to protect public safety from an imminent threat of fire. The agency's own figures show that 11.3 million acres of roadless land are already near existing roads. Lack of access therefore cannot explain why only 5% of high-hazard roadless acreage has been treated since 2014. Limited funding and staff appear more likely. The proposal's purpose and changes extend beyond wildfire policy. The USDA announcement ties the proposal to executive orders directing expanded timber production, energy development, and resource extraction in Alaska. This suggests the rule would mainly open roadless areas, such as Alaska's Tongass National Forest, to commercial extraction. Commercial logging often removes the large, fire-resistant trees that fuel treatments are meant to preserve and protect. The Forest Service also has a multibillion-dollar backlog of deferred road maintenance. Adding roads it cannot maintain would increase erosion and sediment in the streams that supply drinking water to downstream communities. I urge the Forest Service to withdraw the proposed rule, keep the 2001 Roadless Rule in place nationwide, and address wildfire risk through the underused fuel treatments that are already permitted. Thank you for the opportunity to comment.