Comment Analysis · Docket FS-2025-0001

FS-2025-0001-604363

Opposes rescissionA0 noneSubstance 3/24Posted October 7, 2026 On Regulations.gov

Small family — One letter sent by 3 to 9 people, copied or lightly reworded. This comment stands for 3 submissions in its group; the sender added words of their own. See the letter, its submissions and topics.

Scored as the letter — The shared letter of a family, scored once for everyone who sent it.

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

  • Environmental Protection Biodiversity
    • “wilderness areas remain as ecosystem and public servants”
    • “wildlife populations, insects, reduced wildfire risk, and native plant dominance”
    • “permanently dismantle the economical and ecological benefits associate with roadless areas”
  • Water Quality Quantity
    • “essential buffers for water availability”
    • “negative impacts to our local economies and environment”
  • Recreation Tourism Public Use
    • “Traveling to a wilderness area is a spiritual experience”
    • “public recreation in urban-wild land interfaces”
  • Economic Impact Fiscal
    • “negative impacts to our local economies”
    • “environmental impacts associated with forest road construction are severe and expensive”

What it names

Works cited
10.1186/1735-2746-10-23

The comment

Opposition Toward Rescinding the 2001 Roadless Rule As a consulting forester with a bachelors in environmental science, I strongly oppose the USFS decision the rescind the 2001 Roadless Rule. While roads are essential for basic forestry practices; Forestry, let alone bulldozers do not belong in wilderness areas. The value of wilderness areas lies within their resilience. With the 2001 roadless rule in tact, these wilderness areas remain as ecosystem and public servants to current as well as future generations. As climate change continues to push us further into the unknown, these roadless wilderness areas provide essential buffers for water availability, wildlife populations, insects, reduced wildfire risk, and native plant dominance. (Miller Kenton, 1999). As I have seen first hand in my line of work, allowing the construction of roads in these areas will permanently dismantle the economical and ecological benefits associate with roadless areas. The environmental impacts associated with forest road construction are severe and expensive, especially in steep terrain (Caliskan, 2013). I would understand if the USFS decided to allow exceptions to this rule for the purpose of wildfire mitigation and public recreation in urban-wild land interfaces. However, to completely rescind the Roadless Rule is far too broad of a change. It is obvious that this decision is not in favor of the public interest, forest health, natural resource equity, or local economies. With several roadless areas right here in the San Juans, I can confidently say running a bulldozer uphill will have negative impacts to our local economies and environment (Holmes et-al. 2016). Traveling to a wilderness area is a spiritual experience that feels like traveling back in time. The 2001 Roadless Rule is one of the best decisions this country has ever made. To conclude, removing it would be one of this country’s biggest mistakes. Caliskan, E. Environmental impacts of forest road construction on mountainous terrain. J Environ Health Sci Engineer 10, 23 (2013). https://doi.org/10.1186/1735-2746-10-23 International Journal of Wilderness. Miller Kenton, 35-39, 1999). https://scholar.google.com/scholar?hl=en&as_sdt=0%2C6&q=ecological+benefits+of+wilderness+areas&btnG=#d=gs_qabs&t=1791332940345&u=%23p%3DR7-IhIl3-IoJ A synthesis of the economic values of wilderness TP Holmes, …, JM Bowker, …, J Englin, …, E Hjerpe, …, JB Loomis, …, S Phillips, …, R Richardson Journal of Forestry , 2016 https://scholar.google.com/scholar?hl=en&as_sdt=0%2C6&q=benifits+of+wilderness+areas&btnG=#d=gs_md_aa-d&t=1791332621420&u=%2Fscholar%3Fq%3Dinfo%3AKzYOlII3gk0J%3Ascholar.google.com%2F%26scioq%3Dbenefits%2Bof%2Bwilderness%2Bareas%26dv%3D0%26output%3Daa%26ei%3DepDFatK1Ite46rQPmoOZiAE%26scirp%3D2%26hl%3Den

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