Comment Analysis · Docket FS-2025-0001

FS-2025-0001-607623

Opposes rescissionA3 weakSubstance 16/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents the commenter's local standing in Sitka, Alaska, based on subsistence use of deer and salmon, and cites the agency's economic analysis (comparing $4.6–$10.6 million timber benefits against >$100 million impacts and a $6.9 billion road maintenance backlog) to argue that the proposal to rescind the 2001 Roadless Rule is a net negative, while requesting the withdrawal of the proposal and that ANILCA Section 810 subsistence hearings occur prior to any final decision.

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

  • Cultural Heritage Indigenous
    • “ANILCA Section 810 subsistence hearings”
    • “wild food has been at the center of how my family eats”
    • “deer from the forest, salmon from the water”
    • “where our food comes from”
  • Wildlife Habitat
    • “roadless parts of this forest are not empty space”
    • “reason the deer and the salmon are still here”
    • “what the deer and the salmon are worth to a household”
    • “once gone, does not come back”
  • Economic Impact Fiscal
    • “best case for the timber industry at $4.6 to $10.6 million a year”
    • “annual impacts that could exceed $100 million”
    • “$6.9 billion backlog of maintenance on roads”
    • “bad trade on its own terms”

The comment

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

I have lived in Sitka since the 1990s and raised my three sons here. I am writing to ask the Department to withdraw its proposal to rescind the 2001 Roadless Rule (Docket FS-2025-0001, RIN 0596-AD66) and leave the rule as it stands. In the decades since we made our home here, wild food has been at the center of how my family eats: deer from the forest, salmon from the water around us, and boys who grew up knowing where their food comes from. The roadless parts of this forest are not empty space on a map. They are the reason the deer and the salmon are still here, and they are where we have hunted, fished, and gathered for as long as we have lived in this town. The proposal asks us to trade that for very little. The department's own analysis puts the best case for the timber industry at $4.6 to $10.6 million a year, against annual impacts that could exceed $100 million, and it acknowledges that new road building would be limited by budgets and by a $6.9 billion backlog of maintenance on roads that already exist. That is a bad trade on its own terms. What the numbers cannot capture at all is what the deer and the salmon are worth to a household, and that is the part that, once gone, does not come back. The Forest Service plans to hold ANILCA Section 810 subsistence hearings on this proposal. I ask that those hearings happen before any final decision and that what families like mine say in them carry real weight. For us this is not an abstract land-use question. It is a question of where our food comes from and what will be left for our sons. Please withdraw the proposal and leave the rule as it stands. Sincerely, Jenn Lawlor Sitka, Alaska

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