Comment Analysis · Docket FS-2025-0001

FS-2025-0001-610047

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 Evidence.

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

Wildlife Habitat
- “home to countless species of wildlife”
- “fragment ecosystems”
- “vulnerable inhabitants rely on unbroken habitats”
Forest Management Wildfire
- “84% of US wildfires are caused by humans”
- “main vector being roads”
- “proposed rescission would directly result in an increase in wildfires”
Scientific Research Evidence
- “found that 84% of US wildfires are caused by humans”
- “Aplet et al., 2026”
- “agency's stated justification is fundamentally contradicted by such scientific evidence”

The comment

I am writing to express my firm opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule. Growing up, one of my fondest memories was the long drive to Lake Tahoe. It was looking outside and seeing the snow-dusted pine trees, endless blankets of glimmering white, and an occasional deer darting through the brush. These landscapes may be beautiful, but more importantly, they are also the home to countless species of wildlife. Rescinding the Roadless Act would fragment ecosystems like these, whose vulnerable inhabitants rely on unbroken habitats, while invoking irreparable harm to natural and cultural resources. Despite the rescission being proposed to decrease the likelihood of wildfires, it has been found that 84% of US wildfires are caused by humans, with the main vector being roads (Aplet et al., 2026). Thus, the proposed rescission would directly result in an increase in wildfires. Since the agency’s stated justification is fundamentally contradicted by such scientific evidence, the agency should withdraw the counterproductive proposal. Sometimes it’s better to simply take the long route and appreciate the scenic view. I urge the USDA to maintain the current Roadless Area Conservation Rule protections. Thank you for your time and consideration.