Comment Analysis · Docket FS-2025-0001

FS-2025-0001-604583

Opposes rescissionA3 weakSubstance 9/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents the commenter's personal use of specific national forests and wilderness areas, challenges the agency's rationale for repeal by citing Forest Service research on burn rates and existing rule exceptions, and requests the selection of Alternative 1 to maintain the 2001 Roadless Rule.

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

Recreation Tourism Public Use
- “fly fish on the Dry River”
- “Linville Gorge Wilderness area in North Carolina has afforded me some of the greatest adventures”
- “Hunting, fishing and backcountry recreation support rural businesses”
- “quiet, remote, and backcountry recreation values”
Environmental Protection Biodiversity
- “resisted the encroachment of human civilization”
- “last wild backcountry in our public forests”
- “inherently pristine areas of backcountry at an existential level of risk”
- “ecological pain and destruction”
Forest Management Wildfire
- “rule already contains exceptions that allow the agency to build roads... when needed for firefighting”
- “Forest Service's own research found that forests with and without roads burned at similar rates”
- “evidenced based legislation aimed at fire mitigation strategies”
- “marginal, if any benefit”
Public Opinion Support
- “Overwhelmingly public sentiment is in favor of protecting these areas”
- “interests of a few wealthy and powerful interest groups outweigh the overwhelming public sentiment”
- “not very democratic”

What it names

National Forests: George Washington National Forest

The comment

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

To the Forest Service: I am writing to oppose the proposed repeal of the 2001 Roadless Area Conservation Rule and to urge the agency to adopt Alternative 1, which keeps the rule in place. One of the greatest and most valuable resources this country has is its extensive network of public lands. Public lands are owned by all and provide value for all stakeholders. I have grown up largely on the East Coast. One of the first trips I took once I got my drivers license in high school was to drive to George Washington National Forest and fly fish on the Dry River. I didn't know how to fly fish, but I wanted to learn, and this area of public land afforded me that opportunity. I went back multiple times to that same National Forest, always hiking deeper and exploring new sections of river, and since that time I have gone to many more public land areas. The Linville Gorge Wilderness area in North Carolina has afforded me some of the greatest adventures of my life, and I hope one day to bring my children there and to many other public lands. These places exist and have resisted the encroachment of human civilization because politicians in the past have had the courage to protect them. The current proposal seeks to remove protections from roughly 44.7 million acres of national forest land, covering all roadless areas outside Colorado and Idaho. That is a vast share of the last wild backcountry in our public forests, and it belongs to all Americans, not just to those who live near it or profit from it. I understand the stated rationale: that the rule hinders wildfire mitigation and forest health work. But the record does not support it. The rule already contains exceptions that allow the agency to build roads in inventoried roadless areas when needed for firefighting, and it allows certain hazardous fuels work. The Forest Service's own research found that forests with and without roads burned at similar rates since the rule took effect. If this repeal is really about forestry health and management and fire mitigation, then why not state that? Why not propose evidenced based legislation aimed at fire mitigation strategies that are backed by science? I fear that repealing the roadless rule would place these inherently pristine areas of backcountry at an existential level of risk with marginal, if any benefit. Roadless areas are also an economic asset. Hunting, fishing and backcountry recreation support rural businesses, outfitters and guides, and local communities, and they depend on exactly the kind of undeveloped land this rule protects. That value is lost the moment an area is opened to logging and road construction. I learned in elementary school to revere Teddy Roosevelt. Roosevelt had the controversial and courageous idea that the U.S. had a lot of areas worth protecting. And if he didn't protect those areas, then their value and worth would be gone forever. Overwhelmingly public sentiment is in favor of protecting these areas from road building and industrial interests. If the interests of a few wealthy and powerful interest groups outweigh the overwhelming public sentiment that opposes road building, then I would argue that's not very democratic. And the legacy of this administration will be one of ecological pain and destruction that will not be revered by those who come behind us. I urge the Forest Service to select Alternative 1 and keep the 2001 Roadless Rule in place.