Comment Analysis · Docket FS-2025-0001

FS-2025-0001-606251

Opposes rescissionA1 strongSubstance 10/24Owed an answerPosted October 7, 2026 On Regulations.gov

Campaign — One letter sent by 10 or more people, copied or lightly reworded. One of 16 submissions in its group; the sender added words of their own. See the letter, its submissions and topics.

Carries the letter's score — A copy of a family's letter; it holds the score and answerability level of the letter it sent.

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. This rating is the one its shared letter earned.

Owed an answer on 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.
Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
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.

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.
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.

Topics

Recreation Tourism Public Use
- “solitude, viewing natural surroundings”
- “enjoy public land away from roads and vehicle traffic”
- “fishing or hiking”
- “loss of quiet recreation”
Water Quality Quantity
- “clean rivers and lakes”
- “amazing water quality that sustains an incredible fishery”
- “effects of roads on hydrology”
- “impact water quality and quantity”
Wildlife Habitat
- “retaining large, intact landscapes”
- “wildlife that are dependent on large intact landscapes”
- “recovery of the Grizzly Bear”
- “aquatic habitat”
Governance Policy Process
- “NOI and DEIS fail to provide science-based rationale”
- “relying on individual forest planning and management decisions”
- “limitations referred to in the NOI and DEIS”
- “clearly disclose the local recreation and watershed consequences”

What it names

Roadless areas: Copper MountainGrassy Knob
Law cited: 36 CFR Part 294
Works cited: U 2001

Attachments

1 file. Counts as 1 — Counts as one: The attachments enclose no one else's submissions; the comment counts as one.

Own letter

The comment

See attached file: As a South Dakota resident who enjoys using roadless areas, I oppose rescinding the 2001 Roadless Rule. My interest and passion come from experiencing these places. Their value to me includes solitude, viewing natural surroundings, and the opportunity to enjoy public land away from roads and vehicle traffic. Beyond my own personal enjoyment, it is also important to know that we are retaining large, intact landscapes and clean rivers and lakes. These roadless areas deserve consideration and respect. My comment concerns the proposed removal of the protections in 36 CFR Part 294, Subpart B, which restrict road construction, road reconstruction, and timber harvest in inventoried roadless areas, subject to exceptions. USDA proposes relying on individual forest planning and management decisions in place of these national protections. My personal concern is what that change would mean for wildlife, water quality, and landscapes that sustain the activities I enjoy and contribute to my community's economy. (USDA, proposed rule, 91 FR 53827, August 20, 2026.). When I choose a roadless area for fishing or hiking, the undeveloped setting is part of the reason I go. The Copper Mountain and Grassy Knob Roadless Areas in Oregon are representative of a temperate rain forest on extremely steep slopes. Slopes so steep they should be cliffs but are just not quite meet that criteria. These slopes funnel the plentiful near-daily rain into numerous streams that connect in a short distance to the Pacific Ocean. Streams are historically full of salmon such as spring & fall Chinook, coho salmon, and steelhead. I worked in the Oregon Coast Range and fished for steelhead but also listened to other sport and commercial fishermen and communities who were also embedded in the peak of clear-cut logging. Neither better nor worse, but what is critical is sustainability. The practices of that era were not sustainable, as I watched/listened to the fact that salmon runs were declining and visually observed mid-slope logging roads washing out and sending streams of sediment into the rivers and turning streams/rivers that are typically crystal clear into streams/rivers that are the color of chocolate milk. Jobs and healthy economies are important, but they cannot be done at the cost of losing our forest, rivers, and ecosystems. My background and career were in a science-based field, and with that background I am fully aware that a good fishery depends on healthy watersheds. Forest Service research identifies effects of roads on hydrology and aquatic habitat and emphasizes that those effects must be evaluated in their local environmental context. This supports examining individual watersheds rather than assuming that national estimates adequately describe the risks to places people fish. (Gucinski and others, Forest Roads: A Synthesis of Scientific Information, 2001, PNW-GTR-509.) I feel strongly that the NOI and DEIS fail to provide science-based rationale for rescinding a Rule that has been in place for nearly 25 years. A Rule, for example, that protected large intact landscapes for recovery of the Grizzly Bear in the Lower 48. For this reason and so many other reasons, the 2001 Roadless Rule must be retained! I recognize and encourage that where the USDA identifies a specific management problem, it should first evaluate whether existing exceptions or a narrowly tailored approach can address it while preserving roadless characteristics. Over my career in the USDA Forest Service (USDA), I gained a practical working knowledge of Forest Plans (programmatic) and NEPA (site-specific). I acknowledge that Forest Plans vary in age and thus protection for Roadless Areas if “The Rule” is rescinded. More importantly, the limitations referred to in the NOI and DEIS do not tell me whether the places I value would retain equivalent protection over time. The agency should explain what protections would remain; how it accounts for the loss of quiet recreation, how it impacts wildlife that are dependent on large intact landscapes, and how it may impact water quality and quantity. My fishing and hiking experiences have taught me that the character of a place matters as much as the ability to reach it. Once roads and development change that character, the experience may be difficult to recover. I urge USDA to retain the Roadless Rule, address demonstrated management needs through targeted approaches, and clearly disclose the local recreation and watershed consequences of any proposed change. Future generations should have the opportunity to enjoy these public lands as roadless places.