Comment Analysis · Docket FS-2025-0001

FS-2025-0001-606724

Opposes rescissionA2 moderateSubstance 9/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment establishes that the agency's rationale for repealing the Roadless Rule is unsupported by the draft EIS and contradicted by cited scientific studies, while the EIS itself acknowledges significant negative impacts on water, invasive species, and wildlife habitat fragmentation that lack evidence of prevention.

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

A2 moderate: Hard to dismiss — it shows cause and effect.

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.
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.

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.
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
- “home to numerous endangered and threatened species”
- “fragment and damage their habitats”
- “pristine and irreplaceable forests”
Water Quality Quantity
- “threaten clean water supplies”
- “disruption in water relationships”
- “diverting of surface or subsurface flow”
Forest Management Wildfire
- “long-term forest health implications of roadlessness”
- “best available records do not support speculation that roads are needed”
- “spread of invasive plant and insect species”
Public Opinion Support
- “US public overwhelmingly supported adoption”
- “99 percent were generally opposed to the proposed rule rescission”
- “vast majority of people of this country want to keep the Roadless Rule”

What it names

Works cited: 10.1016/j.gecco.2021.e01943Healey 2020Healey 2020Healey 2020

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeEA analysisAnalytical gapEvidenceRequest

Please do not repeal the Roadless Rule. The Roadless Rule protects over 58 million acres of inventoried roadless areas (IRAs) in national forest land from road-building, commercial logging, and other industrial activity. These protections are important and should be maintained. The USDA’s stated Rationale for the Proposal to repeal, i.e., that the “Roadless Rule has limited the Forest Service's ability to conduct vegetation management within inventoried roadless areas and has contributed to the lack of active management of the national forests, which in turn has contributed to challenges in addressing forest health concerns” (1) does not hold up and is not supported by the draft EIS. A study that carefully examined long-term forest health implications of roadlessness in terms of wildfires and invasive species concluded based on Forest Service data that “With the benefit of twenty years of monitoring, the best available records do not support speculation that roads are needed in IRAs to maintain forest health.“ (2). I am concerned that repealing the Roadless Rule would promote the spread of invasive plant and insect species (2). Invasive seeds and pathogens are actively moved along roads via construction equipment, logging trucks, and other vehicles. I am concerned that repealing the Roadless Rule would threaten clean water supplies on which millions of people depend. Inventoried roadless areas are home to numerous endangered and threatened species (3). Construction of roads in these areas would fragment and damage their habitats and contribute to their extinction. The draft EIS for the proposed rule rescission acknowledges on p. 233 that “By removing the Roadless Rule, roads and timber harvest are likely to penetrate much farther into roadless areas, resulting in a greater degree of fragmentation.” In addition, the draft EIS acknowledges on p.79 that “effects could also include long-term impacts such as invasive plant establishment and/or spread, a disruption in water relationships as would occur through diverting of surface or subsurface flow from road construction, or increased erosion potential through ground disturbance, and habitat fragmentation.” No evidence that those effects could be prevented is presented. Please avoid these damaging effects by keeping the Roadless Rule. I am also concerned that repealing the Roadless Rule would lead to the construction of roads through pristine and irreplaceable forests at immense public expense when there is already a huge backlog of maintenance on existing roads. I worry that the new roads would primarily serve the short-term interests of those who would profit from commercial logging and the extraction of minerals and fossil fuels, to the detriment of the environment and the public good. The knowledge that our nation’s roadless national forests exist, and that the native trees, birds, and animals within them are protected by the Roadless Rule, is a highly valuable intangible good that deserves consideration. The US public overwhelmingly supported adoption of the Roadless Rule and overwhelmingly supports keeping it (4). The draft EIS notes that of the comment letters received during the Notice of Intent comment period, approximately 99 percent were generally opposed to the proposed rule rescission. Please do not willfully ignore the evidence that the vast majority of people of this country want to keep the Roadless Rule. Please do not repeal the Roadless Rule. (1) See Published Document: 2026-16965 (91 FR 53827), Federal Register / Vol. 91, No. 160 / Thursday, August 20, 2026 / Proposed Rules, section entitled “Rationale for the Proposed Rule” (p. 53828). (2) See Healey, S. “Long-term forest health implications of roadlessness “ Environmental Research Letters. 15: 104023 (2020). DOI: https://doi.org/10.1088/1748-9326/aba031 (3) See Matthew S. Dietz, Kevin Barnett, R. Travis Belote, Gregory H. Aplet, “The importance of U.S. national forest roadless areas for vulnerable wildlife species”, Global Ecology and Conservation, Volume 32, 2021, e01943, https://doi.org/10.1016/j.gecco.2021.e01943. (4) See “Comment analysis finds over 99% opposition to repealing 2001 Roadless Rule”, report from Center for Western Priorities, September 19, 2025, updated Tuesday, September 23, and sources cited therein. (https://westernpriorities.org/2025/09/comment-analysis-finds-over-99-opposition-to-repealing-2001-roadless-rule/).