Comment Analysis · Docket FS-2025-0001

FS-2025-0001-609350

Opposes rescissionA3 weakSubstance 5/24Owed an answerPosted October 7, 2026 On Regulations.gov

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.

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.
  • Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
  • 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.
  • 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.

Topics

  • Forest Management Wildfire
    • “fire danger will increase with greater human access”
    • “increase access for fire mitigation and landscape scale prevention”
    • “contradicts the Forest Services own findings”
  • Recreation Tourism Public Use
    • “peace and knowledge far deeper than I could ever find in civilization”
    • “visit a place beyond the reach of civilization”
    • “played in, and worked with Roadless Areas”
  • Governance Policy Process
    • “deep backlog of deferred maintenance”
    • “wasteful to create more liabilities for future generations”
    • “Alternative 1 is the wisest choice”

The comment

Secretary Rollins I'm writing to you after a full day of working in a hospital and parenting young children to tell you I oppose the administration proposal to in any way rescind the Roadless Rule. I have lived near, played in, and worked with Roadless Areas for a large chunk of my adult life. They have given me a peace and knowledge far deeper than I could ever find in civilization. They are places that should be off limits, to the greatest possible extent, to the influence of humans. It sounds like a platitude, but I want my children and their children to know what it means to visit a place beyond the reach of civilization, or just know that there is such a place. I believe any attempt to degrade Roadess Area integrity is short sighted and cynically misinformed. I understand that one of the main "arguments" for repealing roadless protections is to increase access for fire mitigation and landscape scale prevention. This contradicts the Forest Services own findings, published in the DEIS which states fire danger will increase with greater human access. I find it baffling that the administration would actively assert otherwise and does not indicate a good faith argument. Sadly that is just the beginning of the horrible and absolutely unnecessary adverse of effects of both Alternatives 2 and 3. For instance it is well known that the Forest Service has a deep backlog of deferred maintenance. How more roads will add to the administrative burden is clear. We have more Forest Service roads than we can handle. It would be wasteful to create more liabilities for future generations to worry about. I am appalled that I have to take from my day to berate my own government about management decisions. It is your job to thoughtfully consider the best choice. You literally have the public resources to do the right thing. Yet here I am after a long day, advocating for one of our most important and valuable resources. I am deeply embarrassed by this administration. It's late y'all. I am almost out of time to get this in and have so much more I wish I could add here. But I'm pressed on time and need sleep. Because of the above stated reasons, I believe that Alternative 1 is the wisest choice, and I firmly oppose Alternatives 2 and 3, or any other attempt to degrade Roadless Area protections.

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