Comment Analysis · Docket FS-2025-0001

FS-2025-0001-603598

Opposes rescissionA3 weakSubstance 12/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents that the agency's analysis fails to fully account for the economic, ecological, and cultural costs of rescinding the 2001 Roadless Rule, specifically citing USDA data on road construction opportunities, wildfire monitoring results, and deferred maintenance costs, while requesting the retention of the rule and selection of the No Action alternative.

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 approximately 58.5 million acres of inventoried roadless areas”
- “wildlife habitat”
- “fragment habitat”
- “non-native plants were twice as common near roads”
Water Quality Quantity
- “clean water”
- “water quality”
- “drinking-water sources”
Tribal Sovereignty
- “Tribal governments consulted opposed rescission”
- “threats to Tribal sovereignty, cultural survival, sacred sites”
- “traditional gathering areas”
- “ancestral homelands”
Recreation Tourism Public Use
- “hunting, fishing, hiking, camping, solitude, scenic values”
- “recreation-related losses”
- “recreational, ecological, cultural, water, wildlife, and economic benefits”
Legal Regulatory Framework
- “NEPA is primarily procedural”
- “Roadless Rule establishes a substantive landscape-scale baseline”
- “removes a national baseline protecting these landscapes”
Forest Management Wildfire
- “Wildfire does not justify nationwide rescission”
- “forests with and without roads burned at similar rates”
- “absence of roads had not prevented fuel-management activities”
Economic Impact Fiscal
- “$6.1 million in annual recreation-related losses”
- “$6.9 billion in deferred road and bridge maintenance”
- “additional construction and long-term maintenance obligations”

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeEA analysisAnalytical gapEvidenceRequestAlternativeLegal

I strongly oppose rescinding the 2001 Roadless Area Conservation Rule and urge the Forest Service to retain it and select the No Action alternative. The Roadless Rule protects approximately 58.5 million acres of inventoried roadless areas across our National Forest System. These lands provide clean water, wildlife habitat, hunting, fishing, hiking, camping, solitude, scenic values, and opportunities to experience public lands without permanent roads and intensive development. The Department describes this proposal as returning decisionmaking to local Forest Service officials. In reality, it removes a national baseline protecting these landscapes from road construction, road reconstruction, and most commercial timber harvesting. USDA’s own analysis acknowledges that rescission could create opportunities for permanent road construction on approximately 18.2 million acres and expand timber-management opportunities on approximately 4.8 million acres of forested roadless areas. It also acknowledges that future forest-plan amendments could expand these impacts. Wildfire does not justify nationwide rescission I support targeted, science-based wildfire mitigation where necessary to protect communities and infrastructure. However, wildfire risk does not demonstrate that protections should be removed from 58.5 million acres. The Forest Service’s own research examining nearly two decades of monitoring found that forests with and without roads burned at similar rates and that the absence of roads had not prevented fuel-management activities in roadless areas. It also found non-native plants were twice as common near roads. Roads may provide access for some fire-management activities, but they also fragment habitat and increase human access and potential ignition sources. If specific areas require treatment, the Forest Service already has authorities and exceptions under the existing rule. NEPA is not a substitute The proposal relies on future NEPA review and existing forest plans as safeguards. These are important, but they do not provide the same protection as the Roadless Rule. NEPA is primarily procedural; it does not prohibit road construction or timber harvesting. The Roadless Rule establishes a substantive landscape-scale baseline before individual projects are proposed. Removing that baseline means the public may have to fight repeatedly, forest by forest and project by project, to preserve landscapes already identified as deserving protection. Economic and infrastructure costs USDA’s analysis estimates approximately $6.1 million in annual recreation-related losses and acknowledges that additional economic effects could exceed $100 million. The analysis should fully account for recreation, tourism, clean water, wildlife habitat, carbon storage, and scenic values that could be lost. The Forest Service also faces approximately $6.9 billion in deferred road and bridge maintenance. Expanding the permanent road network would create additional construction and long-term maintenance obligations. Before opening millions of acres to new roads, the Department should demonstrate why this is financially responsible. Tribal concerns The proposal states that the majority of Tribal governments consulted opposed rescission, citing threats to Tribal sovereignty, cultural survival, sacred sites, traditional gathering areas, water quality, subsistence, and ancestral homelands. These concerns deserve substantial weight. Removing a nationwide layer of protection should not proceed while Tribal governments are warning that it could harm these resources and relationships. Preserve the national baseline Local knowledge is important, but some public-land values are national in character. A national standard prevents roadless areas from receiving dramatically different protection simply because priorities differ between forests or regions. Once a permanent road enters an intact landscape, its fragmentation and development footprint cannot simply be reversed if anticipated benefits fail to materialize. I respectfully request that the Department: 1. Withdraw the proposed rescission and retain the 2001 Roadless Rule. 2. Select the No Action alternative. 3. Fully account for recreational, ecological, cultural, water, wildlife, and economic benefits that could be lost. 4. Demonstrate that rescission is necessary to accomplish wildfire and forest-health objectives that cannot be achieved under the existing rule. 5. Give greater weight to Tribal concerns. 6. Consider the long-term cost of expanding the Forest Service road network. Our national forests belong to all Americans. Inventoried roadless areas are an increasingly rare public resource. We should not trade permanent landscape values for uncertain future opportunities to build roads and harvest timber. I strongly oppose rescinding the 2001 Roadless Area Conservation Rule and urge the Forest Service to retain these protections.