Comment Analysis · Docket FS-2025-0001

FS-2025-0001-608264

Opposes rescissionA3 weakSubstance 10/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents the commenter's opposition to the rescission of the Roadless Rule by citing specific DEIS data regarding road construction costs, species impacts, water quality degradation, and wildfire risks, while asserting standing based on recreation in New York and Vermont.

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 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

Environmental Protection Biodiversity
- “adversely affect 327 threatened and endangered species”
- “provide refuge for vulnerable species”
- “Roadless forests represent some of the most intact, resilient ecosystems”
Water Quality Quantity
- “filter and store clean water”
- “sediment delivered to surface waters is a major source of water quality degradation”
- “Communities across the country would lose protections to their drinking watersheds”
Economic Impact Fiscal
- “leaving taxpayers with billions of dollars in long-term maintenance costs”
- “significantly inflate the deferred maintenance backlog”
- “loss of $9 million in annual visitor spending in local communities”
Governance Policy Process
- “abridged and inadequate public comment process”
- “rushed process that limits and ignores input from citizens, scientists, Tribes, and local communities”
- “undemocratic and deeply irresponsible”

What it names

Roadless areas: Green Mountain

The comment

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

Dear Secretary Rollins, I strongly oppose the USDA’s proposal to fully or partially rescind the Roadless Area Conservation Rule. This reckless action would devastate our public lands, waste taxpayer resources, and undermine the clean water, wildlife habitat, and recreation opportunities that millions of Americans depend on. I urge the Agency to take Alternative 1, the No Action alternative and retain full Roadless Rule protections. I live in New York, NY and spend time recreating in upstate New York, along the Appalachian Trail. Vermont’s Green Mountain National Forest has long been a place I've dreamed of visiting. Under the agency’s proposal, protections for nearly 45 million acres of wild, public lands would be eliminated. The economics of these attacks on the Roadless Rule do not add up. Building new logging roads in remote backcountry areas is extraordinarily expensive, leaving taxpayers with billions of dollars in long-term maintenance costs for roads rarely, if ever, used. According to the DEIS, the Forest Service could build new roads across 18.2 million acres. This would significantly inflate the deferred maintenance backlog, which is already over $6.9 billion according to the DEIS. Further, the DEIS estimates that eliminating the Roadless Rule would degrade roadless areas and backcountry access, resulting in a loss of $9 million in annual visitor spending in local communities. Beyond the economic folly, the environmental consequences are severe. Roadless forests represent some of the most intact, resilient ecosystems left in our country. They filter and store clean water, provide refuge for vulnerable species, and serve as critical carbon sinks in the fight against climate change. The DEIS states that eliminating the Roadless Rule would “adversely affect” 327 threatened and endangered species and 71 designated critical habitats for these species. How would the agency ensure these populations and their habitats aren’t further degraded without protection of the Roadless Rule? The DEIS also states that “Road construction and native surface forest roads are the largest source of sediment related to timber harvest operations, and sediment delivered to surface waters is a major source of water quality degradation.” Communities across the country would lose protections to their drinking watersheds. How would the agency ensure that these watersheds remain intact and that water sources are not compromised from increased risk of erosion and sedimentation? Once roads and clearcuts fragment these landscapes, the damage is permanent. In the DEIS, the agency admits that “Road density is linked to human-caused wildfires, and as the density of roads increases so does the probability, number, and frequency of wildfire ignitions.” Recent studies have found that fires are 4 times more likely to start near a road than in a roadless area. I am concerned that removing Roadless Rule protections would increase fire risk in our nation’s backcountry forests. Lately, I am appalled by the USDA’s decision to pursue this rollback through an abridged and inadequate public comment process. The original Roadless Rule was created after the most extensive public engagement process in the history of federal rulemaking, with over 95% of commenters supporting strong protections. During last fall’s comment period on the Notice of Intent, over 600,000 Americans submitted public comments, with over 99% of comments opposing the proposed rescission of the rule. During the legally required Tribal consultation process, the agency found that “the majority sentiment among Tribal governments consulted is opposition to the proposed rescission. Its analysis concedes that timber harvest and road construction in these areas “could have long-term negative effects on Tribal rights and interests.” Now, the agency is attempting to dismantle these protections through a rushed process that limits and ignores input from citizens, scientists, Tribes, and local communities. This is undemocratic and deeply irresponsible for decisions of such sweeping consequence. Despite the shortened comment periods, the American public has already made their voice clear: keep the Roadless Rule in its full form in place. For more than two decades, the Roadless Rule has been a cornerstone of sound forest management, balancing ecological, economic, and cultural values. Instead of rolling back protections, the agency should strengthen its commitment to protecting America’s roadless forests for the clean water, climate resilience, recreation, and biodiversity they provide. For the reasons listed above, fully or partially rescinding the Roadless Rule under Alternatives 2 and 3 of the draft EIS would be a grave mistake. I oppose the proposal to rescind or alter the Roadless Rule, and support Alternative 1, the No Action alternative.