Comment Analysis · Docket FS-2025-0001

FS-2025-0001-607559

Opposes rescissionA1 strongSubstance 11/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents that the DEIS fails to justify full rescission of the 2001 Roadless Rule, specifically noting that the rule's existing exceptions (36 CFR 294.12) allow for wildfire response, and argues that the public comment process was inadequate compared to the original rulemaking, while requesting the adoption of Alternative 1 (no action) to protect water quality and wildlife habitat in the Monongahela and George Washington National Forests.

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, 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

Recreation Tourism Public Use
- “no road noise”
- “backcountry where ruffed grouse, brook trout, and black bear still have room”
- “large unroaded landscapes accessible to roughly ten million people”
Water Quality Quantity
- “intact headwater streams you can drink from with a filter”
- “headwaters feed the Potomac River that supplies drinking water to millions”
- “protects water quality at the source by preventing the sediment, culvert failures, and runoff”
Governance Policy Process
- “The process itself has been inadequate”
- “no public meetings in the affected forests”
- “overwhelming majority of more than 600,000 commenters supported keeping the rule”
Economic Impact Fiscal
- “building and maintaining new roads it cannot afford”
- “road maintenance backlog measured in the billions of dollars”
- “shifts cost to taxpayers while delivering most of the benefit to private extraction interests”

What it names

National Forests: George Washington National Forest Monongahela National Forest
Law cited: 36 CFR 294.12

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

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

I am writing to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and to ask the Department to select Alternative 1 (no action) in the final decision. I have spent time in the Monongahela National Forest, including Dolly Sods and the Cranberry Wilderness, as well as the George Washington National Forest. What makes those places worth the drive from Sharpsburg is precisely what this proposal would strip away: no road noise, intact headwater streams you can drink from with a filter, and backcountry where ruffed grouse, brook trout, and black bear still have room. Those areas are within two to three hours of the Baltimore-Washington corridor, which means they are some of the only large unroaded landscapes accessible to roughly ten million people. Opening them to road construction trades a permanent public asset for a short-term private one. I live in Sharpsburg, Maryland, in the Potomac watershed. The nearest inventoried roadless areas to my community sit in those same forests, whose headwaters feed the Potomac River that supplies drinking water to millions of people downstream, including in Washington County. Roadless backcountry protects water quality at the source by preventing the sediment, culvert failures, and runoff that come with new road construction on steep forest ground. Maryland does not have a national forest, but it lives downstream of several, and that is why this rule matters here. The DEIS does not justify a full rescission. The 2001 rule already contains exceptions for road construction needed for wildfire response, public health and safety, and other circumstances (36 CFR 294.12), so the claim that the rule blocks fire management does not hold up against the rule's own text or the agency's own history of approving treatments in roadless areas. If the Department believes specific areas need site-specific flexibility, the lawful path is a targeted amendment or state-specific rulemaking with full analysis, as Idaho and Colorado did, not a nationwide repeal that removes protection from roughly 45 million acres at once. Rescission would also commit the Forest Service to building and maintaining new roads it cannot afford. The agency already carries a road maintenance backlog measured in the billions of dollars. Adding mileage in remote terrain shifts cost to taxpayers while delivering most of the benefit to private extraction interests. The process itself has been inadequate. The original 2001 rule followed more than 120 days of public comment and hundreds of public meetings. This rescission was given roughly 30 days plus a 15-day extension, with no public meetings in the affected forests, for a decision affecting a quarter of the national forest system. The record from the 2025 scoping period, in which the overwhelming majority of more than 600,000 commenters supported keeping the rule, should be given real weight rather than treated as a formality. Please retain the 2001 Roadless Rule in full and adopt Alternative 1.