Comment Analysis · Docket FS-2025-0001

FS-2025-0001-613379

Opposes rescissionA0 noneSubstance 5/24Posted 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

A0 none: Counted, not answered.

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
    • “human-caused fire ignitions are 7-8 times denser on roaded than on roadless lands”
    • “fuel management activities in roadless areas have actually been more numerous”
    • “Speculation that eliminating road prohibitions would improve forest health is not supported by nearly twenty years of monitoring data”
  • Environmental Protection Biodiversity
    • “extensive damage that logging, clearcutting, and roadbuilding will have upon delicate ecosystems”
    • “protect our land from predation by private interests”
    • “irreparable public harm”
  • Economic Impact Fiscal
    • “cost of building new roads is staggering”
    • “projected revenue gain is only $4-$11 million per year nationwide”
    • “direct comparison of revenues minus the costs of development, maintenance, and ecological harm”
  • Water Quality Quantity
    • “damage... upon delicate ecosystems, watersheds”
    • “vulnerable and priceless ecological environments”

What it names

Works cited
Healey 2020

The comment

I am writing to state my opposition to the recission of the 2001 Roadless Rule. As a Pacific Northwest American Indian that was raised in Oregon and has volunteered countless hours learning about and practicing forest conservation techniques and strategies, I can state unequivocally that the reasons being given by the current regime's USFS decision to terminate the Roadless Rule are so blatantly false and contradictory of their own data that they can't even begin to dissemble the regime's true intent of following through with their traitorous pattern of plundering our collective commons for the benefit of wealthy private capital. The USFS's reasoning to terminate the Roadless Rule directly contradicts data and conveniently ignores salient information that aims to downplay the damage termination of the rule will cause and/or overstate the financial benefits. Here are just a few clear examples of how the USFS's reasoning falls apart under the lightest of scrutiny: 1. DEIS data shows that human-caused fire ignitions are 7-8 times denser on roaded than on roadless lands. Meanwhile, fire response times are only a few percentage points higher (97 vs 92) on roaded than on roadless lands. The manyfold increase in fire likelihood greatly overshadows the incremental gain in access to wooded areas that might be threatened by fire. 2. Research cited by the agency in 'Long-term forest health implications of roadlessness' by Sean P Healey in 2020 state clearly: "Agency management records show that a lack of roads has not stopped fire prevention measures; fuel management activities in roadless areas have actually been more numerous on a per-square kilometer basis than elsewhere in the National Forest System, although activities in areas with roads cover larger areas. Historical fire maps indicate that forests with and without roads have burned at similar rates since the Rule took effect.... Speculation that eliminating road prohibitions would improve forest health is not supported by nearly twenty years of monitoring data." 3. The cost of building new roads is staggering when roads that we currently have are chronically underfunded. The DEIS's stated figures for road development stand at $80,000-$100,000 per mile plus an additional $5000-$50,000 per mile just in annual maintenance. The projected revenue gain is only $4-$11 million per year nationwide. Before opening these vulnerable and priceless ecological environments for logging, the public deserves a direct comparison of revenues minus the costs of development, maintenance, and ecological harm. These examples don't even make mention of the extensive damage that logging, clearcutting, and roadbuilding will have upon delicate ecosystems, watersheds, and wild animal resources that our public depend on. Therefore, it is in the public (as well as the government's) best interest to maintain the Roadless Rule to protect our land from predation by private interests that stand to privately benefit at the cost of irreparable public harm. I must insist that Alternative 1 is the only sensible decision in this matter and No Action against the Roadless Rule should therefore be taken. Sincerely, Garth D Henry

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