Comment Analysis · Docket FS-2025-0001

FS-2025-0001-602266

Opposes rescissionA0 noneSubstance 6/24Posted 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

A0 none: Counted, not answered.

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

  • Wildlife Habitat
    • “adversely affect 327 threatened and endangered species”
    • “71 designated critical habitats”
    • “Bull trout, Chinook salmon, Chum salmon, Coho salmon”
    • “Marbled murrelet, Northern spotted owl”
  • Water Quality Quantity
    • “Threaten Water Quality”
    • “inventoried roadless areas typically have good water quality”
    • “sediment delivered to surface waters is a major source of water quality degradation”
    • “receive drinking water from watersheds fully or partially within IRAs”
  • Recreation Tourism Public Use
    • “Loss in Recreation and Visitor Spending”
    • “degrade roadless areas and backcountry access”
    • “loss of $9 million in annual visitor spending”
  • Tribal Sovereignty
    • “Undermines Tribal Interests”
    • “majority sentiment among Tribal governments consulted is opposition”
    • “long-term negative effects on Tribal rights and interests”

The comment

To Whom it May Concern. I fully oppose the plan to rescind the Roadless Area Conservation Rule, both partially and fully. I am a U.S. citizen and teacher living in Los Angeles, CA. According to the administration’s DEIS, eliminating the Roadless Rule would: 1. Cause a Loss in Recreation and Visitor Spending: The administration estimates that eliminating the Roadless Rule would degrade roadless areas and backcountry access to millions of acres, resulting in a loss of $9 million in annual visitor spending in local communities. 2. Imperil Wildlife: Eliminating the Roadless Rule would “adversely affect” 327 threatened and endangered species and 71 designated critical habitats for these species. In Oregon, this includes listed species such as Bull trout, Chinook salmon, Chum salmon, Coho salmon, Marbled murrelet, Northern spotted owl, Oregon silverspot butterfly, Oregon spotted frog, Sierra Nevada red fox, and steelhead, among others. 3. Threaten Water Quality: According to the DEIS, “… inventoried roadless areas typically have good water quality due to limited disturbance,” and “Road construction and native surface forest roads are the largest source of sediment related to timber harvest operations, and sediment delivered to surface waters is a major source of water quality degradation.” Communities like Bend, Eugene, La Grande, Ashland, and others in Oregon receive drinking water from watersheds fully or partially within IRAs. 4.Spread Invasive Species: The DEIS states that increased road construction and timber harvest are likely to “introduce and spread invasive plant species due to ground disturbance.” Invasive plants tend to be more flammable, leading to higher wildfire risk, and can outcompete native plant species. 5. Undermines Tribal Interests: During the legally required Tribal consultation process, the administration found that “the majority sentiment among Tribal governments consulted is opposition to the proposed rescission.” Its analysis concedes that timber harvest and road construction in these areas “could have long-term negative effects on Tribal rights and interests.” 6. Could Increase Fire Risk: The administration admits “Road density is linked to human-caused wildfires, and as the density of roads increases so does the probability, number, and frequency of wildfire ignitions.” Recent studies have found that fires are 4 times more likely to start near a road than in a roadless area. 7. Add to Infrastructure Backlog: According to the DEIS, the Forest Service could build new roads across 18.2 million acres (44.5% of current IRAs) in the short term. This would significantly inflate the deferred maintenance backlog, which is already over $6.9 billion. Again, for these reasons I oppose the proposal to rescind or alter the Roadless Rule and support Alternative 1, the No Action alternative. We are in a climate crisis. Time to act like it. Best, Amanda Ackerman

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