Comment Analysis · Docket FS-2025-0001

FS-2025-0001-603800

Opposes rescissionA3 weakSubstance 8/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment establishes that the commenter, a climber using national forest lands, opposes the rescission of the 2001 Roadless Area Conservation Rule, arguing that the agency's analysis fails to justify the change due to negative economic impacts (recreation loss vs. timber gain), maintenance backlogs, and insufficient wildfire safeguards, while noting that most Tribal governments consulted oppose the rescission.

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.

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

Recreation Tourism Public Use
- “I am a climber, and I use national forest land for climbing and other recreation all the time”
- “The undeveloped, roadless character of these places is the reason I go”
- “New roads and logging would permanently change the backcountry areas that I and many other climbers, hikers and campers rely on”
- “estimates at most $11.4 million a year in added timber revenue to the government, against an estimated $6.1 million a year in lost recreation value”
Governance Policy Process
- “Leaving protection to individual forest plans is not an equivalent safeguard”
- “Plans can be amended forest by forest, and the proposal admits later amendments could open more land than the draft EIS analyzes”
- “A national rule gives the durable, consistent protection that people, communities and businesses have relied on since 2001”
- “The agency's own analysis does not justify this change”
Forest Management Wildfire
- “Wildfire does not justify repeal either”
- “The 2001 rule already allows cutting small-diameter trees to reduce wildfire risk”
- “Building new roads it cannot afford to maintain is not responsible management”
- “the proposal acknowledges that more road access can increase human-caused ignitions”
Tribal Sovereignty
- “the Department reports that most Tribal governments it consulted oppose the rescission”
- “That should carry real weight”

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequestAlternative

I oppose rescinding the 2001 Roadless Area Conservation Rule (RIN 0596-AD66) and ask the Department to select the no-action alternative. I am a climber, and I use national forest land for climbing and other recreation all the time. The undeveloped, roadless character of these places is the reason I go. New roads and logging would permanently change the backcountry areas that I and many other climbers, hikers and campers rely on. The agency's own analysis does not justify this change. It describes the new management opportunities as modest and localized, and estimates at most $11.4 million a year in added timber revenue to the government, against an estimated $6.1 million a year in lost recreation value. Meanwhile the Forest Service has a $6.9 billion backlog of road and bridge maintenance. Building new roads it cannot afford to maintain is not responsible management. Wildfire does not justify repeal either. The 2001 rule already allows cutting small-diameter trees to reduce wildfire risk, and allows roads needed to protect public health and safety from imminent threats such as fire. If those exceptions are slow or inconsistently used, the fix is to streamline them, not eliminate the rule. The proposal itself acknowledges that more road access can increase human-caused ignitions. Leaving protection to individual forest plans is not an equivalent safeguard. Plans can be amended forest by forest, and the proposal admits later amendments could open more land than the draft EIS analyzes. A national rule gives the durable, consistent protection that people, communities and businesses have relied on since 2001 for clean drinking water, wildlife habitat and backcountry recreation. Finally, the Department reports that most Tribal governments it consulted oppose the rescission. That should carry real weight. Please keep the 2001 Roadless Rule in place.