Comment Analysis · Docket FS-2025-0001

FS-2025-0001-607532

Opposes rescissionA1 strongSubstance 13/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment establishes that the proposed rule's rationale is contradicted by its own data (Tables 14 and 21) and requests a factual correction, the evaluation of an alternative that retains the 2001 Roadless Rule with streamlined exceptions, and the non-rescission of the rule based on public opposition and habitat concerns.

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, Evidence, Alternative, 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

Legal Regulatory Framework
- “contradicted by the analysis printed in the document proposing it”
- “request a factual correction to the Rationale for the Proposed Rule under 7 CFR 1b.7(f)(2)(v)”
- “alternative that retains the 2001 Roadless Rule while streamlining the review and approval process”
- “7 CFR 1b.7(h)(3) requires the agency to state its reason”
Environmental Protection Biodiversity
- “immense habitat loss”
- “Populations of nearly every species of wildlife are in decline”
- “These precious areas must be left as untouched as possible for future generations”
Climate Carbon Storage
- “time of significant and worsening climate change”
- “change the default from "don't build" to "build roads" on these priceless public lands”
Public Opinion Support
- “the public response is overwhelmingly opposed to rescission of the roadless rule”
- “who is the ultimate owner of these lands? The public”

What it names

Law cited: 36 CFR 294.12(b)36 CFR 294.13(b)(1)7 CFR 1b 7 CFR 1b.7(h)

The comment

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

To Whom It May Concern: I respectfully request that you do not rescind the Roadless Rule, for many reasons. I will set out just a few here. First, The rationale for the proposed rule is not merely unsupported; it is contradicted by the analysis printed in the document proposing it. I request a factual correction to the Rationale for the Proposed Rule under 7 CFR 1b.7(f)(2)(v), reconciling it with Table 14, Table 21, and the activity figures at pp. 14–15 — either by withdrawing the forest-health causal chain, or by stating, region by region and against those tables, where roadless designation is in fact associated with worse forest-health outcomes than active management. The correction cannot be deferred to project-level NEPA: the assertion is a rule-level justification, it appears in the rule’s rationale rather than in any effects analysis, and it is the premise against which alternatives were eliminated from detailed study as failing the purpose and need. If the FEIS retains the assertion, it should state which acres, in which regions, the tables are said to support it on, and where in the record the agency’s response is accounted for under 7 CFR 1b.7(f)(3). Second, because 36 CFR 294.13(b)(1)(ii) (2001) already authorizes the fire-risk and forest-health treatment the purpose and need in the proposed rule identify, an alternative that retains the 2001 Roadless Rule while streamlining the review and approval process for exceptions under 36 CFR 294.12(b) and 294.13(b) (2001) - including the national tracking of requests, approvals, denials, and processing times whose absence the DEIS concedes at p. 14 - will meet the stated need without rescission. I request that this alternative be developed and evaluated under 7 CFR 1b.7(f)(2)(ii). If it is not carried forward, 7 CFR 1b.7(h)(3) requires the agency to state its reason; a reason that the alternative does not meet the purpose and need is unavailable while the purpose and need rests on the misstatement identified in item 1 and the unsupported causal claim identified in item 3. Because the Rationale for the Proposed Rule is also the agency's explanation for reversing a position it has maintained since 2001, I direct this concern to the final rule preamble as well as to the final environmental impact statement. There are many examples in the proposed rule of unsupported justifications and assertions contradicted by the agency's own data, too many to list here in detail within the character limitations. Important data are missing. Generally, rescission of the roadless rule will change the default from "don't build" to "build roads" on these priceless public lands in a time of significant and worsening climate change and immense habitat loss. Populations of nearly every species of wildlife are in decline. The government has not proved the need to increase roads in these areas. Finally, the public response is overwhelmingly opposed to rescission of the roadless rule. And who is the ultimate owner of these lands? The public. These precious areas must be left as untouched as possible for future generations. Thank you.