Comment Analysis · Docket FS-2025-0001

FS-2025-0001-603981

Opposes rescissionA1 strongSubstance 9/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment establishes that the agency's rationale for rescinding the Roadless Rule is unsupported by evidence of local management needs, as the existing rule already contains exceptions for health, safety, and wildfire mitigation, and requests the agency to provide specific examples of blocked actions or retain the national baseline.

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

A1 strong: Must be answered — it names the law.

Owed an answer on Analytical gap, Legal.

Standard dismissals it defeats

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.
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.

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.
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.
Outside the scope The agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.

Topics

Governance Policy Process
- “prioritizing local decision-making over a uniform national rule”
- “shifts a heavy burden onto the public, who must track and comment on many separate local decisions”
- “A national rule exists so the public does not have to fight the same question in every forest”
- “address them through targeted, site-specific changes with full public notice”
Water Quality Quantity
- “354 municipal watersheds contributing drinking water to millions of people”
- “People in every state rely on these lands for water”
Climate Carbon Storage
- “They store large amounts of carbon in mature and old forests”
- “Alaska's Tongass, among the most intact temperate rainforests on Earth”
Environmental Protection Biodiversity
- “rely on these lands for water, wildlife, and recreation”
- “Retain 36 CFR part 294, subpart B as the national baseline”
- “keep the 2001 Roadless Rule”

What it names

Law cited: 36 CFR 294.12(b)(1)36 CFR 294.13(b)(1)36 CFR part 294 66 Fed. Reg. 3244

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Local knowledgeEA analysisAnalytical gapEvidenceRequestAlternativeLegal

RE: Docket FS-2025-0001, RIN 0596-AD66, proposed rescission of 36 CFR part 294, subpart B Introduction My family has held a Forest Service recreation residence permit since the 1930s. Our cabin is on one national forest, but I see the Roadless Rule as larger than any single place. I am commenting on the agency's stated goal of prioritizing local decision-making over a uniform national rule. Background USDA has said the rescission would "prioritize local agency decision-making over regulatory rules that are the same across the country." My comment addresses whether that rationale holds up, given how the 2001 rule actually works. Analysis The 2001 rule is not a rigid ban. It allows roads to protect public health and safety in cases of imminent threat of flood, fire, or other catastrophic event (36 CFR 294.12(b)(1)). It allows cutting of generally small-diameter timber to improve habitat or reduce wildfire risk (36 CFR 294.13(b)(1)). It respects existing rights. Local forest managers have used these provisions for twenty-five years. The rule sets a baseline and leaves real room for local judgment. Without a national baseline, each roadless area will be defended one project or forest plan at a time. That shifts a heavy burden onto the public, who must track and comment on many separate local decisions, often with little notice. Some areas will be lost simply because no one had the time or resources to respond to a particular proposal. A national rule exists so the public does not have to fight the same question in every forest. The values at stake are national. The 2001 rule found that roadless areas include 354 municipal watersheds contributing drinking water to millions of people (66 Fed. Reg. 3244, Jan. 12, 2001). They store large amounts of carbon in mature and old forests. They include places such as Alaska's Tongass, among the most intact temperate rainforests on Earth. People in every state rely on these lands for water, wildlife, and recreation, whether or not they live near them. I also ask the agency to explain which specific local management needs the current rule has prevented, with examples. If the existing exceptions have been enough, then the local decision-making rationale does not justify rescission. Recommendations 1. Retain 36 CFR part 294, subpart B as the national baseline and select the no-action alternative. 2. If particular forests face specific needs, address them through targeted, site-specific changes with full public notice, rather than removing protection nationwide. 3. Publish examples of local management actions the rule has actually blocked since 2001. Conclusion The current rule already balances national protection with local flexibility. Please withdraw this proposal and keep the 2001 Roadless Rule.