Substantive Analysis

2001 Roadless Rule Revision

Counting comments is only the start. Every substantive comment is read and scored for what it actually contributes — evidence, legal argument, engagement with the environmental analysis, alternatives, and specific requests. The document those comments engage is on the site too: the annotated DEIS walks the agency’s draft analysis issue by issue, with sample comments on each identified issue.

How substantive is the input?

Share of the 280,787 substantive comments that meaningfully do each of the following.

Makes a specific request
3%
Identifies an analytical gap
1%
Draws on first-hand local knowledge
1%
Offers an alternative
0%
Cites specific evidence
1%
Names a specific place
51%
Cites law or regulation
0%
Engages the environmental analysis
5%

How hard are they to dismiss?

A substance score says how much a comment contains. It does not say whether the agency can set it aside. Federal rules let an agency answer a comment by saying the analysis already covers it, that it shows no cause and effect, or that it is not substantive at all — and the four things that make a comment substantive are not equally good at surviving those replies. A comment that names a statute is the hardest to dismiss; one that only asserts a problem is the easiest.

These are the 54,419 comments rated so far. It is a smaller number than the comment counts elsewhere on this page: where thousands of people sent the same campaign letter, that letter is rated once rather than once per signature.

A1 — cites the law itself — the agency cannot say the analysis already covers it, and cannot certify it as non-substantive
1%
A2 — shows a cause and effect, or offers an alternative — a “no cause and effect” dismissal cannot reach it
2%
A3 — substantive, but every standard dismissal is still available
2%
A0 — does not clear the substantive bar — counted, not answered
94%

By substance score band — the cells off the diagonal are the point. A short comment citing a statute must still be answered; a long, detailed one with no legal or causal hook can be set aside.

A1A2A3A0strong6100developed236614817marginal1975811,1235,598minimal101227345,779

What the strongest comments are about

Every substantive comment is scored; the top tenth within each stance (4,679 exhibits) is the “gold” set. This is how those exhibits’ topic mix differs from the substantive pool they are drawn from — bars to the right are topics the strongest comments raise more often than the pool, to the left less often (percentage points).

Water Quality Quantity+25.0Forest Management Wildfire+24.9Recreation Tourism Public Use+14.0Economic Impact Fiscal+11.1Legal Regulatory Framework+9.7Wildlife Habitat+8.8Governance Policy Process+8.3Tribal Sovereignty+3.4Scientific Research Evidence+1.9Cultural Heritage Indigenous+1.1National Security Public Safety-0.0Climate Carbon Storage-0.5Public Health Wellbeing-0.8Public Land Access Rights-1.0Public Opinion Support-1.7Sentiment Only-1.9Resource Development Extraction-6.1Environmental Protection Biodiversity-17.2

How comments are scored

A strong public comment does more than register an opinion. A model reads each substantive comment and scores it 0–3 on eight things — 3 means the comment does that thing clearly and well, 0 means not at all — the eight add up to a substance score out of 24. In the exhibits below, the passages that earned points are shaded in the category’s colour — the same colours shown in the score panel above each comment.

Local knowledge — Draws on a first-hand connection to the place — visits, sustained activity, occupation, or a professional role.
Evidence — Backs claims with specific facts, data, or research.
Legal — Cites statutes, regulations, or legal obligations.
EA analysis — Engages the agency's environmental analysis directly.
Analytical gap — Identifies something the analysis fails to address.
Alternative — Proposes a different course of action.
Request — Makes a specific, actionable request of the agency.
Specific place — Names a specific location — from a region down to an exact creek, trail, road, or map reference.

The strongest opposing comments

The 10 opposing comments with the highest substance scores. Each opens with its scorecard, then the comment with its scored passages shaded — hover a mark to see what it earned.

Substance score19 / 24A1 · Must be answered — it names the law
Local knowledge1 / 3
Evidence3 / 3
Legal2 / 3
EA analysis3 / 3
Analytical gap3 / 3
Alternative2 / 3
Request2 / 3
Specific place3 / 3
Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001

Twenty-six years of owning a cabin at Lake Quinault have given me a clear picture of what is at stake in the South Quinault Ridge roadless area and across the Olympic National Forest. The old growth stands of Douglas Fir, Spruce, and Cedar that surround the lake in this temperate rainforest are not abstract policy objects. They are what I return to. Building roads for access into this mountainous terrain will likely increase erosion and degrade water quality and the salmon habitat. I oppose rescission of the 2001 Roadless Area Conservation Rule and file these comments for Docket FS-2025-0001.

Public lands should be managed for conservation of old growth stands and water resources, public recreation, and resource use, with balance among these purposes. The Roadless Rule provides that balance. So much of the national forests are already open to development and logging, and what remains of our roadless forests should remain a high priority so future generations can experience them and have the opportunity for quality water sources. Washington holds 139 inventoried roadless areas totaling 2,014,832 acres, and the South Quinault, and Moonlight Dome areas within the Olympic National Forest represent exactly the irreplaceable country this rule was written to protect.

The proposal justifies rescission partly on permitting and administrative burden, but the rule as written already contains flexibility. It generally banned road building subject to limited exceptions, including "the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." I ask the agency to identify which specific burdens fall outside these existing exceptions and quantify them, on the record, before using regulatory burden as a reason for nationwide rescission.

The agency is also selling this action as wildfire protection, but its own effects analysis contradicts that framing. "Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads." That is more than seven times the ignition rate on roaded land. The agency must quantify the expected increase in human-caused ignitions resulting from new road access and weigh it explicitly against the claimed reduction in wildfire hazard before that rationale can bear any weight.

Its own accounting makes the contradiction worse. The agency's Cost Benefit Analysis Table 4 (p. 30) lists among the qualitative unquantified costs of this proposal: "Degraded recreation quality; ecological and water impacts; increased ignition risk; agency road maintenance burden." In the benefits column, "reduced wildfire risk" sits among the benefits the agency says it cannot quantify. The promise of fire reduction is unquantifiable; the cost of increased ignition risk is acknowledged but also left unquantified, beside data showing roaded land burns at a far higher human-caused rate. The agency must quantify the net wildfire effect of this action in either direction before wildfire can serve as any justification for it.

There are so many existing back-country roads already in disrepair and needing brush clearing, drainage work, and surface repair to make them passable. Our tax dollars would be better spent repairing and maintaining the roads that already exist than building more into country that has none. Across the Pacific Northwest region, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. Roads and their facilities can produce the overwhelming majority of sediment from a timber sale, and removing riparian vegetation can raise stream temperatures beyond what suits cold-water species, reducing egg survival, rearing densities, and growth of coho salmon in what the agency's own materials describe as Essential Fish Habitat and critical habitats managed by NMFS. The South Quinault Ridge stands above a watershed where these consequences are not theoretical.

Finally, the agency's stated purpose is to reduce regulatory burden and return decision-making to local officials, not fire management. The overlap with the wildland-urban interface as defined by HFRA is 9.8 million acres, 24 percent of the affected area, and the DEIS itself says the benefits of added fuel-management access "would likely be modest and localized." The agency constructed and then rejected a WUI-targeted alternative that would have addressed the fire rationale without eliminating protection for the remaining 76 percent of affected roadless acres. The agency must explain, in plain terms, why that narrower alternative was set aside in favor of nationwide rescission.

Sincerely,
Barbara Bailey
Tacoma, WA

In short: The comment establishes that the agency's justification for rescinding the Roadless Rule is contradicted by its own data showing higher human-caused ignition rates on roaded land, and requests that the agency quantify the net wildfire effects and specific regulatory burdens on the record before proceeding with nationwide rescission.

Substance score19 / 24A1 · Must be answered — it names the law
Local knowledge2 / 3
Evidence1 / 3
Legal2 / 3
EA analysis3 / 3
Analytical gap3 / 3
Alternative2 / 3
Request3 / 3
Specific place3 / 3
I regularly visit the inventoried roadless areas of the Sam Houston National Forest in Texas (Big Creek, Winters Bayou, Big Woods, Little Lake Creek) and formerly visited the San Bernardino National Forest.

I oppose the rescission and comment on both the proposed rule and the Draft EIS. I request a specific response to each numbered item in the Final EIS.

1. The cost-benefit analysis does not support the action

The preamble estimates annual recreation losses of about $6.1 million against $5.2-11.4 million a year in Treasury and Forest Service revenue, a figure assuming harvest across every operable acre, which the Department calls unlikely. It states these against a $6.9 billion road maintenance backlog, and concedes impacts could exceed $100 million.

The FEIS should state plainly whether the projected timber revenue exceeds the lifecycle maintenance cost of the roads required to obtain it. If it does not, the economic rationale fails.

2. The wildfire rationale is contradicted by the Rule's text

36 C.F.R. § 294.13(b)(1)(ii) already permits cutting generally small diameter timber to maintain or restore ecosystem composition and structure, such as to reduce the risk of uncharacteristic wildfire effects. Section 294.12(b) permits roads for public health and safety. Nothing restricts prescribed fire, managed wildfire, hand thinning, or mastication. Small diameter material is what fuels reduction targets; the Rule restricts commercial removal of large trees, which is not fuels reduction.

The preamble concedes that greater public access can increase human caused ignition potential. The Department cites the Rule's statement that such cutting "is expected to be infrequent," but that states an expectation, not an operative limit: it sets no cap and adds no approval condition.

I therefore request that the FEIS identify, by project name, forest, and year, each hazardous fuels project in the last ten years a responsible official could not implement solely because of the 2001 Rule. Without this list, the stated purpose lacks record support under Motor Vehicle Mfrs. Ass'n v. State Farm, 463 U.S. 29 (1983).

3. The treatment statistic does not establish causation

The low treatment rate in high hazard roadless acreage since 2014 is equally consistent with appropriation limits, workforce capacity, and WUI prioritization. The preamble itself says budget and physical constraints will limit road construction after rescission, conceding the constraint is fiscal. The FEIS must analyze these rather than assume the Rule is the cause.

4. Reliance interests are unaddressed

The Department invites comment on reliance interests. Reversing a twenty five year policy requires more detailed justification where serious reliance interests exist (FCC v. Fox Television, 556 U.S. 502 (2009); Encino Motorcars, 579 U.S. 211 (2016)). Land management plans were revised against this backdrop and allocated timber production elsewhere; recreation businesses, outfitters, and water providers invested on the same assumption. The proposal analyzes none of it.

5. "This rule authorizes nothing" does not excuse NEPA analysis

The Department justifies rescission by its expected effects while failing to analyze them. Its own figures, permanent roads newly permissible across 18.2 million acres and temporary across 11.3 million, are foreseeable consequences NEPA requires it to examine. The FEIS must quantify sediment and drinking water impacts, ESA effects and § 7 status, and cumulative effects with the reinstated Alaska Roadless Rule and E.O. 14225 timber targets.

6. The range of alternatives is inadequate

The DEIS carries forward only three alternatives: no action and two rescission variants. No intermediate conservation alternative was analyzed in detail, including those Tribes requested. The FEIS must analyze:

(a) retaining the Rule while broadening and streamlining the § 294.13(b)(1)(ii) fuels exception near the WUI, with mandatory temporary-road decommissioning

(b) a state and Tribal petition process

(c) delegating exception approval to forest supervisors, with deadlines

(d) geographically limited rescission supported by unit-level evidence

7. The process is inadequate

The Department allows 30 days for a proposed rule, three volume Draft EIS, and cost benefit analysis governing 58.5 million acres, with hearings only in Alaska under ANILCA § 810. Of 64 Tribal consultation requests, 29 have been held, and the Department acknowledges majority Tribal sentiment opposes the rescission.

I request a comment period of no fewer than 90 days, hearings in each affected state, and completed tribal consultation before any final action.

Requested action: withdraw the proposal and retain 36 C.F.R. Part 294, Subpart B. Alternatively, extend the comment period, hold hearings outside Alaska, complete consultation, and analyze the item 6 alternatives.

Respectfully submitted,
an anonymous member of the public

In short: The comment establishes that the proposed rule contains deficiencies in its cost-benefit analysis, wildfire rationale, treatment statistics, reliance interest analysis, NEPA compliance, range of alternatives, and public comment process, and requests specific procedural and substantive changes to the rulemaking.

Substance score18 / 24A1 · Must be answered — it names the law
Local knowledge2 / 3
Evidence2 / 3
Legal2 / 3
EA analysis3 / 3
Analytical gap3 / 3
Alternative1 / 3
Request2 / 3
Specific place3 / 3
Subject: Technical Comment on Evidentiary Deficiencies: Roadless Rule Proposed Rescission (91 FR 35421; Docket FS-2025-0001)

I am a Buncombe County, NC resident who was significantly impacted by Hurricane Helene and who regularly hikes in and around the Pisgah Mountains and Bent Creek Experimental Forest. As such, I am deeply concerned about the inevitable damages to my community, region and beyond that would be caused by a rescission of the Roadless Rule. The below is a detailed update to my initial comment posted yesterday, August 20th, 2026.

I formally demand that the U.S. Forest Service select the "No Action" alternative and withdraw the proposal to rescind roadless protections. The August 20, 2026, DEIS fails to take the "hard look" required by NEPA (42 U.S.C. § 4321). Proceeding on this record would be arbitrary, capricious, and a violation of the Administrative Procedure Act (5 U.S.C. § 706(2)(A)).

The following deficiencies must be resolved before a Final EIS is published:

1. Outdated Post-Disaster Baseline: The DEIS violates 40 C.F.R. § 1502.15 by relying on pre-disaster data. Nearly two years after Tropical Storm Helene, the slopes of Craggy Mountain, Big Ivy, and Harper Creek are structurally altered by severe landslides and geologically unstable. Proposing timber roads on failing slopes ignores active local conditions and contradicts the agency's 2023 Revised Land Management Plan for the Pisgah and Nantahala National Forests.

The Forest Service must pause this process and coordinate with the North Carolina Geological Survey to map post-Helene landslide risks before acting further.

2. Omission of Municipal Infrastructure Costs: Under Loper Bright Enterprises v. Raimondo, courts no longer grant deference to unsupported agency assumptions; the burden of proof belongs to the Forest Service. The French Broad River Basin supplies drinking water to 100,000+ Asheville area residents. Roads and logging on storm-damaged slopes will surge sediment loading, shifting filtration costs onto local ratepayers. This omission also violates Goal 2 of the agency’s 2026–2030 Climate Adaptation Plan.

The agency must consult the Asheville Water Resources Department and disclose a quantified estimate of water treatment cost increases imposed on ratepayers.

3. Unaddressed Road Maintenance Backlogs: Under the State Farm precedent (463 U.S. 29), an agency decision that ignores a central part of the problem cannot stand. The Forest Service carries a multi-billion-dollar road maintenance backlog.

The USFS must place into the record the exact dollar backlog for the Grandfather Ranger District and the Appalachian Ranger District office in Mars Hill, explaining how building new roads is defensible when it cannot fund the upkeep of failing roads outside its own district office.

4. Wildfire Rationale Contradicts Regional Science: In humid, high-rainfall forests of Western North Carolina, roads are a wildfire delivery mechanism, not a firebreak. Decades of data show human-caused ignitions (vehicle sparks, equipment, unattended campfires) expand with road access into backcountry.

The Forest Service must disclose the predictive modeling and methodology used to conclude new roads will not increase wildfire risks to communities like Asheville.

5. Skipped Endangered Species Consultation: Road construction and canopy fragmentation will alter high-elevation microclimates critical to the federally endangered Spruce-Fir Moss Spider and Carolina Northern Flying Squirrel. The Endangered Species Act requires formal Section 7 consultation before an action proceeds.

The Forest Service must halt this rulemaking until Section 7 consultation with the USFWS is completed.

Data Quality Act Request: Pursuant to the Data Quality Act, I formally request that the Forest Service release the raw GIS datasets and predictive software used for the DEIS. If the agency lacks localized, post-Helene geological and hydrological data for the Pisgah-Nantahala, it must disclose that gap rather than proceed as though it does not exist.
The DEIS was built on a baseline that no longer exists. Until the Forest Service accounts for post-Helene ground conditions, water filtration impacts, its maintenance backlog, regional fire science, and its ESA obligations, the only defensible choice is the "No Action" alternative.

In short: The comment establishes that the DEIS for the Roadless Rule rescission is legally deficient because it relies on pre-Hurricane Helene data, omits municipal water treatment costs and road maintenance backlogs, contradicts regional wildfire science, and fails to conduct required Endangered Species Act Section 7 consultations for the Spruce-Fir Moss Spider and Carolina Northern Flying Squirrel.

Substance score18 / 24A2 · Hard to dismiss — it shows cause and effect
Local knowledge3 / 3
Evidence3 / 3
Legal0 / 3
EA analysis3 / 3
Analytical gap3 / 3
Alternative1 / 3
Request2 / 3
Specific place3 / 3
I am a forest scientist who researches wildfire and heat/drought impacts on western US forests in OR, WA, CA, and CO. I am writing to strongly object to the proposed removal of the roadless rule, which purportedly is about reducing wildfire risk. This is FALSE - the rescinding of the roadless rule is really a timber and deregulation rule that mentions fire but is not about fire at all. Fire ignition data, including the USFS's 2001 finding that roads increase human-caused fire, rebut the rationale behind this proposed change. People start most fires in the American west. Increased public road access will raise the number and frequency of wildfires, without doubt. And USFS forest management plans already restrict harvest on 26.7 million acres regardless of the roadless rule. Additionally, the USFS cannot even maintain the forest roads it has already built, as it has a roughly $6.9 billion maintenance backlog on its roads!

In addition, the proposed change makes NO economic sense and is wasteful to American taxpayers like myself. The USFS' own cost-benefit analysis shows a net present value range of negative $92 million to positive $199 million over fifteen years. The timber benefit of $9.9 to $22.0 million has to be weighed against $6.1 million in recreation losses and $5.3 to $11.5 million in forgone passive use. And there is a glaring arithmetic error: Table 1 lists minimum annual forgone benefits as $5.3 million while footnote 6 says costs include both the $6.1 million recreation loss and the $5.3 to $11.5 million passive use loss. The minimum should be $11.4 million!

Critically, the biological assessment is a draft and incomplete. Even the draft finds this action is likely to negatively impact at least 300 listed species and some 45 designated critical habitats. The impacted species include grizzly bears, wolverines, gray wolves, Canada lynx, Mexican wolves, and fisher cats. Section 7 of the draft consultation is incomplete. A 30-day comment period based on on an incomplete biological assessment is not a lawful basis for a final rule.

In conclusion, I am urging you to select Alternative 3, or better yet, no change to the Rule. The USFS' own analysis shows that limiting rescission to within a half mile of existing roads and the wildland-urban interface captures roughly 80% of the timber benefit on a fraction of the footprint — this is exactly where the fire prevention rationale is strongest! Why is the propsoal not focused on this if it's about fire? Also, please consider alternatives that multiple tribes requested that the agency did not analyze.

Thank you.

In short: The comment establishes that the proposed rescission of the roadless rule is factually unsupported by fire data, contains a specific arithmetic error in Table 1 regarding forgone benefits, relies on an incomplete biological assessment and Section 7 consultation, and fails to analyze tribal-requested alternatives, thereby documenting a significant deficiency in the agency's analysis.

Substance score18 / 24A1 · Must be answered — it names the law
Local knowledge1 / 3
Evidence3 / 3
Legal2 / 3
EA analysis3 / 3
Analytical gap3 / 3
Alternative1 / 3
Request2 / 3
Specific place3 / 3
Comment on Proposed Rescission of the 2001 Roadless Area Conservation Rule
Docket: FS-2025-0001 | RIN: 0596-AD66 | 91 FR 53827 (Aug. 20, 2026)

I am a resident of Whatcom County, Washington. I fish the Nooksack and Skagit systems, and I do riparian restoration work on a salmon-bearing tributary in the Tenmile watershed with the Whatcom Conservation District. I oppose the proposed rescission and urge the Department to select the No Action alternative.

I am writing to identify one specific and serious gap in the Draft Environmental Impact Statement, and to request the methodology behind one economic figure.

The DEIS contains no watershed-scale aquatic effects analysis for ESA-listed salmonids.

The DEIS concludes that the proposed rule "is not expected to have a significant change to the commercial fishing or fish-processing industries" and offers no meaningful analysis of effects on listed salmonids in Puget Sound watersheds. That conclusion is not supported by the record, and it is inconsistent with the agency's own prior analysis.

Road construction, reconstruction, and associated harvest are among the best-documented sources of sediment delivery, altered hydrology, and elevated stream temperature in Pacific Northwest forested watersheds. The Forest Service compiled that record itself in the 2001 Roadless Rule Final EIS, where protection of high-quality headwater watersheds was a central justification for the rule. The Department cannot rescind a rule premised in part on aquatic protection without addressing the aquatic analysis it previously relied on.

In the inventoried roadless areas of the Mount Baker-Snoqualmie National Forest, three points require analysis that the DEIS does not provide:

Bull trout. The Coastal-Puget Sound distinct population segment is listed as threatened, with designated critical habitat overlapping IRAs in the Nooksack and Skagit drainages. Bull trout are among the most thermally sensitive salmonids in North America and depend on cold, low-sediment headwater habitat of exactly the type these IRAs contain. The DEIS does not analyze effects on critical habitat primary constituent elements.

Chinook and steelhead. Puget Sound Chinook and Puget Sound steelhead are both ESA-listed. The North Fork and South Fork Nooksack support the last remaining early-timed Chinook populations in the basin. These are a recovery priority and are already sediment and temperature limited. Additional road-derived sediment in the upper watershed acts on populations with no margin.

Northwest Forest Plan Aquatic Conservation Strategy. Many of these IRAs sit within Key Watersheds and Riparian Reserves. The DEIS does not analyze how rescission interacts with ACS objectives or with the watershed condition and road density standards that follow from them.

I request that the Department prepare a watershed-scale aquatic effects analysis for the Pacific Northwest region and complete ESA Section 7 consultation with NMFS and USFWS on this programmatic action before issuing a final rule. The statement that local decisions "would remain subject to the substantive requirements of the Endangered Species Act" does not discharge the obligation to analyze the effects of the decision being made now.

I would add one point the DEIS raises against itself. It acknowledges a $6.9 billion deferred maintenance backlog for roads and bridges. An unmaintained forest road is not a management tool. It is a chronic sediment source and a failure liability, and the agency's own budget history indicates new roads will join that backlog rather than clear it.

The DEIS estimates recreation losses at "an estimated $6.1 million annually." That is roughly fourteen cents per acre per year across 44 million acres, against a national outdoor recreation sector the Bureau of Economic Analysis places near $1.2 trillion in output. The Department has asked commenters for data and analytic methods. I ask the same of the Department: disclose the valuation model, the unit values applied, the source study, and the treatment of non-market and passive use values. As presented, the figure cannot be evaluated or challenged, which is itself a defect in the disclosure.

Requested action
- Select the No Action alternative and retain 36 CFR part 294, subpart B.
- At minimum, prepare a supplemental DEIS containing a watershed-scale aquatic effects analysis for ESA-listed salmonids in the Pacific Northwest, and complete Section 7 consultation.
- Disclose the methodology underlying the recreation valuation.
- Extend the comment period. Thirty days is not commensurate with a rulemaking affecting 44 million acres.

In short: The comment establishes that the Draft EIS fails to provide a watershed-scale aquatic effects analysis for ESA-listed salmonids in the Nooksack and Skagit watersheds, specifically regarding bull trout, Chinook, and steelhead, and requests the disclosure of the methodology behind the $6.1 million annual recreation loss estimate.

Substance score18 / 24A1 · Must be answered — it names the law
Local knowledge2 / 3
Evidence3 / 3
Legal2 / 3
EA analysis3 / 3
Analytical gap2 / 3
Alternative0 / 3
Request3 / 3
Specific place3 / 3
Dear Ms. Rollins:

As an outdoor enthusiast, I write to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and to note that the Department's statutory obligations under the Multiple Use — Sustained Yield Act and the National Forest Management Act require a genuine accounting of the non-commodity values the Rule protects — an accounting that the proposed rescission's record has not provided.

I've been lucky to call the PNW home for the last 26 years and the Larch and Gifford Pinchot areas around the Gorge and Mt. Hood mean more to me than can adequately be expressed. I urge to resist the fascistic impulse to acquiesce towards corporations with nothing to offer beyond the carving up of our shared outdoor resources.

We live in an area that is still dealing with the impacts of the Celilo Falls destruction. I urge you again to reconsider allowing additional development in an effort to boost the bottom lines of short term corporate interests. Like the falls, once these resources are destroyed we cannot get them back.

Regarding the Larch in the Mt. Hood National Forest, Oregon:

The threat mechanism classified as 4.1 - Roads & railroads (IUCN-CMP 4.1) is actively degrading habitat for Cascade Torrent Salamander (Rhyacotriton cascadae, G3) in the Larch Inventoried Roadless Area, Mt. Hood National Forest, at Serious - slight severity across Restricted (11-30%) scope.

The persistence of Cascade Torrent Salamander in Larch under current threat levels presumes continued roadless conditions. Road construction fundamentally alters this baseline, converting the landscape from one that constrains 4.1 - Roads & railroads to one that accelerates it.

NEPA requires the agency to take a hard look at the effects of rescission on Cascade Torrent Salamander (Rhyacotriton cascadae) in the Larch IRA. The DEIS fails this standard without site-specific analysis of 4.1 - Roads & railroads at the severity and scope documented by NatureServe.

"The expansion of road networks degrades the slope stability and further increases the susceptibility to landslides. Deforestation, infrastructure construction, and mining triggered about 16% of fatal landslides from 2004 to 2016. High overlap exists between landslide susceptibility and areas of endemism for mammals, birds, and amphibians, which means that forests protecting both biodiversity and landslide risks to human society are important conservation targets."
— Proceedings of the National Academy of Sciences, 2022

The "No Direct Effect" Framing Is Contradicted by the Assessments' Own "Reasonably Certain" Findings and by the Record

The USFWS Biological Assessment frames the action at page 377: "The Forest Service has determined that rescinding the Roadless Rule will have no direct effect on ESA-listed resources because it does not authorize, fund, or carry out future forest management activities." The same document undoes that framing. Page 376: "it is reasonably certain that active forest management and road construction will increase in these areas." Page 24: "it is reasonably certain to occur that there would be an increase in new proposals for uses involving road construction or reconstruction." And the agency's own Tribal Summary Impact Statement records the decisive rejoinder (p. 2): "The Hopi Tribe noted that removing prohibitions, in itself, has an impact." An agency may not deconstruct a programmatic action into harmless paperwork while its own documents find the consequences reasonably certain; reasonably foreseeable effects of removing a prohibition are effects of the action. 42 U.S.C. § 4332(2)(C); Kern v. U.S. Bureau of Land Mgmt., 284 F.3d 1062 (9th Cir. 2002) (programmatic NEPA analysis may not defer all effects); Ocean Advocates v. U.S. Army Corps of Eng'rs, 402 F.3d 846 (9th Cir. 2005). I request the FEIS analyze the reasonably certain increase its own assessments find, rather than resting on the no-direct-effect formulation.

The Rule has protected these forests across multiple administrations. I'm asking this one to do the same.

Respectfully,

CommentID: RLC-20260909-YP9YL1

In short: The comment establishes that the proposed rescission of the 2001 Roadless Area Conservation Rule lacks a required NEPA 'hard look' analysis regarding the reasonably certain increase in road construction and its specific impacts on the Cascade Torrent Salamander in the Larch Inventoried Roadless Area of the Mt. Hood National Forest, contradicting the agency's 'no direct effect' framing with its own biological assessments and cited scientific data.

Substance score17 / 24A2 · Hard to dismiss — it shows cause and effect
Local knowledge2 / 3
Evidence2 / 3
Legal0 / 3
EA analysis3 / 3
Analytical gap3 / 3
Alternative2 / 3
Request2 / 3
Specific place3 / 3
Walking through Ramsey's Draft restores health and wonder. I have gone there for decades and appreciate the lush wildness, and that experience, along with my concern for the Augusta and West Augusta regions and the wild places like The Priest, Three Ridges, and St. Mary's that I take my young grandchildren to see, is the basis for this comment opposing the proposed rescission of the 2001 Roadless Area Conservation Rule.

The agency asserts in its Rationale for the Proposed Rule that "The 2001 Roadless Rule limited the Forest Service’s ability to conduct vegetation management within inventoried roadless areas and has contributed to the lack of active management of the national forests, which has contributed to challenges in addressing forest health concerns." That claim is not reconciled with what the document itself reports elsewhere: that the rule did not meaningfully constrain fuel treatments as a share of forested land, and that insect and disease risk in western roadless areas is similar to or lower than on managed forest land outside those designations. The soil in places like Ramsey's Draft is rich, lush, and supports numerous wildflowers and salamanders that thrive in moist conditions, precisely the kind of ecosystem the existing data suggests is not unusually at risk. The agency must reconcile its forest health rationale with those findings before it can justify rescission on those grounds.

The contradiction deepens when the document's own data are examined directly. At Table 14, the agency acknowledges that "Insect and disease risk is generally higher in western regions; in western forests, the percent of forests at risk is similar or lower in potentially affected IRAs when compared to NFS forests outside of designated areas." The agency uses insect and disease pressure as a primary driver of this proposal, yet its own figures show that already-roaded, already-accessible non-designated National Forest System lands carry greater risk. I want the agency to explain, in the final rule, why rescinding protections for inventoried roadless areas is the preferred remedy when the risk is demonstrably higher on lands where active management is already permitted, and to analyze whether directing increased management to those non-designated lands would achieve the same objectives at lower ecological cost.

The range of alternatives the agency chose to study also warrants scrutiny. The document states that "An alternative that considered maintaining existing inventoried roadless area boundaries and prohibitions on permanent road construction while allowing temporary road construction and timber harvest was considered but eliminated from detailed study as not being responsive to the purpose and need," as noted in the Alternatives Considered but Eliminated from Detailed Study section. That rationale is circular: a purpose and need written to require deregulation will, by definition, exclude any alternative that retains meaningful protection. The agency should provide a non-circular justification, grounded in its actual fire and forest health objectives, for why an approach allowing temporary-road-based hazardous fuel treatment and selective harvest without permanent road construction cannot meet those objectives, and should consider adding such an alternative to the range of detailed study in the final environmental impact statement.

It is easy to see the impact of roads and tree clearing on shared water sources in the Augusta and West Augusta regions, where protected waters and farmland with agricultural runoff are already under pressure. The opportunity to experience wildness in undeveloped spaces that can only be reached on foot is something I bring my grandchildren to these forests for, and it is not possible in a highly developed landscape. The agency should address each of these points fully before this rule proceeds.

In short: The comment documents that the agency's proposed rescission of the 2001 Roadless Rule contains internal contradictions, specifically that its own data (Table 14) shows insect and disease risk is similar or lower in roadless areas compared to non-designated lands, and that the elimination of a temporary-road alternative was based on a circular rationale, thereby requiring the agency to reconcile these findings and justify the exclusion of that alternative in the final rule.

Substance score17 / 24A2 · Hard to dismiss — it shows cause and effect
Local knowledge1 / 3
Evidence3 / 3
Legal0 / 3
EA analysis3 / 3
Analytical gap2 / 3
Alternative2 / 3
Request3 / 3
Specific place3 / 3
The roadless areas of the Grand Mesa Uncompahgre Gunnison National Forest are where I hike, camp, backpack, snowshoe and ski. They are the buffers to my favorite Wilderness Areas and invaluable habits and corridors for wildlife as well as sensitive plants. Though I live in Colorado and the rescission of the 2001 Roadless Area Conservation Rule (Rule) will not affect the state where I live, I recreate, wildlife watch and seek solitude in roadless areas across the country. These landscapes belong to all of us regardless of where we live. I vehemently oppose the rescission of the Rule and the agency's own documents make the case against this proposal better than I can.

The Recreation and Scenery section of the draft EIS shows, at Table 41, that "The majority (90 percent) of the potentially affected IRAs are either primitive, semi-primitive non-motorized, or semi-primitive motorized recreation settings." I personally advocated for these designations during our forest plan revision and know the value of these settings. The same document's Social and Economic section records substantial visitor expenditures in affected areas, and the background data indicates that national forests containing inventoried roadless areas receive approximately 125 million of the 164 million total annual National Forest System visits. Despite that, the purpose and need statement never weighs the claimed regulatory burden reduction against the concrete risk of degrading the recreation settings that generate those visits and that local spending. The agency should explain, in the final EIS, how many of the primitive and semi-primitive acres documented at Table 41 are projected to shift to roaded-natural or more developed recreation opportunity spectrum classes under each action alternative over a 20-year horizon, and should quantify what that shift means economically for recreation-dependent communities like the ones near the Grand Mesa Uncompahgre Gunnison.

The agency's treatment of alternatives is equally difficult to accept. The draft states that an alternative maintaining existing inventoried roadless area boundaries and prohibitions on permanent road construction while allowing temporary road construction and timber harvest was eliminated from detailed study as not being responsive to the purpose and need. That rationale is circular. The purpose and need was written to require deregulation, so it excludes by definition any alternative that preserves meaningful protections. The agency should explain in non-circular terms, in the final EIS, why an alternative built around temporary-road-based hazardous fuel treatment and selective harvest inside inventoried roadless areas cannot meet the stated fire and forest-health objectives, and should add such an alternative to the range of alternatives studied in detail.

I have attended presentation by wildland firefighters and have read scientific research about wildfire mitigation. Science and firefighters agree that this proposed rescission is not based in science related to wildfire mitigation. We know that the majority of wildfires start alongside or with close proximity to roads and firefighter organizations like FUSEE oppose rescission of the Rule. More roads mean more fires; Ecosystem integrity and prohibition of road construction and motorized use in designated roadless areas help prevent wildfires.

Clean water, wildlife habitat, and the primitive character of these places are not abstractions to me. The agency must address all these factors. Thank you for your consideration of my objection to rescission of the Rule.

In short: The comment establishes that the draft EIS fails to quantify the economic and recreational impacts of shifting primitive settings to developed classes, relies on a circular purpose and need statement to exclude a viable alternative involving temporary roads for fuel treatment, and ignores scientific evidence that road construction increases wildfire risk.

Substance score17 / 24A1 · Must be answered — it names the law
Local knowledge1 / 3
Evidence3 / 3
Legal2 / 3
EA analysis2 / 3
Analytical gap3 / 3
Alternative0 / 3
Request3 / 3
Specific place3 / 3
Dear Department of Agriculture Leadership:

As someone who grew up at Lake Tahoe and has built a lot of my outdoor life around what's available in roadless public land, I'd say this rule has done more for what I value about those places than any other single policy.

The Grouse Lakes area was one of the first places I ever backpacked, and my family has been visiting it for decades to enjoy the solitude and pristine wild character of the area. It helped spark a lifelong love for the outdoors and wilderness which has enriched my life in countless ways.

Wagon Wheel lakes has been an especially important place in my life. My father and I used to visit these lakes regularly, and now that he has passed away, it's a place where I feel close to him. We both loved how peaceful and pristine this area was, it's unique quality would be irreparably harmed by road access.

Should the roadless rule be rescinded, the Grouse Lakes area, along with countless other special natural areas would be forever altered. Their defining quality, that of peaceful isolation would be irreversibly lost. This area holds a special place in my life, it's a place to relax and reconnect with my essential human spirit, and this is only possible because it is not easy to access. The lack of roads makes this place what it is a peaceful haven away from the world.

Regarding the Grouse Lakes in the Tahoe National Forest, California:

NEPA requires that cumulative impacts be assessed across connected resources, not within arbitrary administrative boundaries. Grouse Lakes and East Yuba in Tahoe National Forest — 21.0 miles apart, sharing 5 climate-threatened species and 23,648 acres of 2 ecosystem types — constitute a single climate refugia network that must be evaluated as such.

The connected roadless landscape between Grouse Lakes and East Yuba in Tahoe National Forest currently provides exactly the climate refugia function that the agency's own NOI identifies as at risk. 5 climate-threatened species occupy 2 undisturbed ecosystem types spanning ~23,648 acres. This is not theoretical refugia — it is functioning refugia that roadless protection maintains.

Without network-level analysis of the Grouse Lakes–East Yuba refugia corridor in Tahoe National Forest, the DEIS cannot accurately assess what rescission costs. The 5 shared climate-threatened species, the 2 shared ecosystem types, and the ~23,648 acres of connected refugia represent a climate adaptation resource that area-by-area review will systematically fail to account for.

"Seed dispersal over sufficiently large distances can maintain ecological resilience in fragmented landscapes and buffer changes in local-scale functional diversity. Otherwise, functional diversity is maintained by local processes, meaning that ecological resilience of isolated forest fragments depends strongly on land use type and intensity. Habitat fragmentation and local disturbances jointly operate on ecological resilience at different scales. Forest fragments acting as intermediate stepping stones in the transfer of seeds maintained functional diversity across the landscape."
— Diversity and Distributions (Wiley), 2016

Failure to Substantively Respond to Content of Majority-Opposition Comments

The Notice of Intent section reduces overwhelming public opposition to a bare percentage, stating that "approximately 99 percent were generally opposed to the proposed rule recission, while approximately 1 percent were generally in support," without any accompanying discussion of what those commenters actually said. No substantive response section addressing the content categories raised — water quality, carbon storage, invasive species spread — appears associated with this passage. Independent research the agency should engage directly documents that roads cause "increased mortality from road construction," "spread of exotic species," and sediment delivery that is "long-lasting and cumulative and cannot be effectively mitigated" (Trombulak & Frissell 2000). Did the agency consider comments raising these documented mechanisms, and if so, where in the record is that consideration explained? Reducing majority opposition to a percentage without engaging its substance violates the requirement that agencies give reasoned consideration to public comment under Vermont Yankee Nuclear Power Corp. v. NRDC, 435 U.S. 519 (1978), and is arbitrary and capricious under APA 5 U.S.C. § 706(2)(A). I request a substantive, topic-by-topic response to the content of majority-opposition comments before this rescission is finalized.

What the Roadless Rule has preserved over the past two-plus decades can't be rebuilt once it's gone. Please don't rescind it.

Yours sincerely,

CommentID: RLC-20260907-DCQ5KU

In short: The comment establishes that the agency's DEIS fails to assess the Grouse Lakes–East Yuba climate refugia corridor as a single network, and that the Notice of Intent's reduction of public opposition to a percentage without substantive engagement of specific content categories (water quality, carbon storage, invasive species) violates NEPA and the Administrative Procedure Act.

Substance score17 / 24A2 · Hard to dismiss — it shows cause and effect
Local knowledge1 / 3
Evidence3 / 3
Legal0 / 3
EA analysis3 / 3
Analytical gap3 / 3
Alternative2 / 3
Request2 / 3
Specific place3 / 3
I camp and hike with my dog, my friends in the Mount Lemmon area of the Coronado National Forest. I come back with photographs and memories of the wildflowers, birds, and deer around my campsite. These are the places and the moments I am writing to defend, because the proposed rescission of the 2001 Roadless Area Conservation Rule threatens exactly what makes those landscapes worth visiting.

The agency's alternatives analysis is built on a circular foundation. The purpose and need statement was written to require deregulation, and then any alternative that keeps meaningful protections in place was eliminated because it failed to satisfy that deregulation-centered purpose. The notice documents this plainly, stating in the Alternatives Considered but Eliminated from Detailed Study section that "An alternative that considered maintaining existing inventoried roadless area boundaries and prohibitions on permanent road construction while allowing temporary road construction and timber harvest was considered but eliminated from detailed study as not being responsive to the purpose and need." That rationale proves nothing. It defines away every middle-ground option before analysis begins. An alternative built around temporary-road-based hazardous fuel treatment and selective harvest inside inventoried roadless areas without permanent road construction could plausibly satisfy the stated fire and forest-health objectives. The agency has not shown otherwise. I ask that the agency explain in the final EIS, in non-circular terms, why such an alternative cannot meet those objectives, and add it to the detailed study range.

The recreation impacts of this decision are also inadequately analyzed. The document's own Table 41 shows that "The majority (90 percent) of the potentially affected IRAs are either primitive, semi-primitive non-motorized, or semi-primitive motorized recreation settings." These are the conditions that draw millions of visitors, support local economies, and sustain the kind of quiet, wildlife-rich camping I value in the Coronado. Yet the purpose and need statement does not weigh regulatory relief against the risk of degrading the recreation settings that produce those visits and that spending. The final EIS should analyze how many primitive and semi-primitive acres are projected to shift to roaded or more developed recreation opportunity spectrum classes under each alternative over a 20-year horizon, and should quantify the economic consequences for communities whose livelihoods depend on those settings. The agency should explain how it accounts for those losses.

The plan-reliance rationale that anchors alternatives 2 and 3 is also unsupported. The agency acknowledges in the Potentially Affected Environment section that "45 of those were revised between 2001 to 2011 when the status of the Roadless Rule was uncertain due to litigation. Therefore, these plans are less likely to have incorporated IRAs into their management areas or provided specific direction for these areas." The agency simultaneously offers land management plans as the primary safeguard replacing the roadless rule while conceding that most plans were built without adequate inventoried roadless area direction. That is not a safety net. The final EIS should identify which specific plan amendments or revisions would be required to provide equivalent protection in each affected region, and rescission should not be finalized before those updates are either in place or secured by a binding completion schedule.

The forests and lands, once destroyed, cannot be resurrected, and the accompanying loss of wildlife, waters, and biodiversity affects the natural circle of life which we humans are a part of. The wildflowers and birds I photograph at Mount Lemmon, and the places like the Grand Canyon, Ironwood Forest Monument, Imperial National Wildlife Refuge, and San Pedro Riparian National Conservation Area that I care about, deserve analysis that looks past short-term regulatory convenience and reckons honestly with what is at stake for future generations.

In short: The comment establishes that the agency's alternatives analysis is circular by eliminating protective options based on a deregulation-centered purpose, fails to quantify the degradation of primitive recreation settings and associated economic impacts using data from Table 41, and relies on land management plans that were explicitly acknowledged as lacking specific direction for inventoried roadless areas.

The strongest supporting comments

The 3 supporting comments with the highest substance scores, shaded the same way. Support comments score lower overall — exhibits are the top of each side (the 90th percentile within that sentiment), so these are the strongest of a lower distribution.

Substance score12 / 24A3 · Substantive, but easier to set aside
Local knowledge3 / 3
Evidence1 / 3
Legal0 / 3
EA analysis1 / 3
Analytical gap2 / 3
Alternative0 / 3
Request2 / 3
Specific place3 / 3
I am submitting this comment as a livestock grazing permittee on the Sycamore allotment, Prescott National Forest, in the Verde River watershed. I depend directly on National Forest System roads to manage my permit — moving and gathering cattle, maintaining stock tanks and other water developments, checking and repairing fence, and meeting the terms of my grazing permit. I ask that as this rule making moves forward, and as any resulting forest-plan or project-level decisions are made, the agency keep two things squarely in view.

1. Protect ranching access and infrastructure explicitly.
Returning roadless-area decisions to individual forest plans and project-level review, as this proposal does, should not put existing ranching access at risk. The roads and routes permittees currently rely on to administer their allotments — including in inventoried roadless areas — are working infrastructure, not incidental use. I ask that the Forest Service commit, in guidance implementing any rescission, that (a) existing routes needed to administer active grazing permits remain open and maintainable without new procedural barriers, (b) permittees are treated as cooperating stakeholders — not just members of the general public — in any forest-plan-level roads analysis that follows this rule change, and (c) maintenance or reconstruction of a road needed to reach a stock tank, water development, or allotment boundary is not treated the same as new road construction for other purposes.

2. Don't open more roads than the agency can maintain.
The proposed rule itself acknowledges a $6.9 billion deferred maintenance backlog for Forest Service roads and bridges. That backlog is not an abstraction where I ranch — roads I already depend on are washed out, rutted, or impassable because there has never been funding to maintain them properly. Rescinding the roadless rule without a funded maintenance plan risks making this worse, not better: every mile of new road opened for recreational access (OHV routes, dispersed camping spurs, etc.) is a mile added to a system the agency has already shown it cannot keep up. Recreational traffic accelerates wear on shared routes — the same roads ranchers use to move cattle and equipment — and when there's no maintenance budget behind that added use, degradation compounds and eventually falls back on permittees to work around washed-out or unmaintained roads just to do routine allotment work.

I am not opposed to local, project-level decision-making replacing a blanket national rule — in principle, that flexibility could serve ranching interests better than a one-size-fits-all prohibition. But flexibility without funding is not flexibility, it's deferred cost shifted onto the roads people already use. I ask that any decision to open new roads in former roadless areas — particularly for recreation — be paired with a real maintenance funding commitment, and that expanding the road network not be prioritized ahead of maintaining the routes that grazing operations, and other working uses of the forest, already depend on.

In short: The comment establishes that the commenter is a livestock grazing permittee on the Sycamore allotment in the Verde River watershed who relies on National Forest System roads for permit administration, and documents the specific risk that rescinding the roadless rule without a funded maintenance plan will exacerbate the $6.9 billion deferred maintenance backlog, thereby degrading the working infrastructure required for grazing operations.

Substance score11 / 24A1 · Must be answered — it names the law
Local knowledge1 / 3
Evidence0 / 3
Legal2 / 3
EA analysis1 / 3
Analytical gap2 / 3
Alternative2 / 3
Request2 / 3
Specific place1 / 3
**To:** Director, Ecosystem Management Coordination, USDA Forest Service

**Docket ID:** FS-2025-0001 (Document ID: FS-2025-0001-223869)

**Regulation Identifier Number (RIN):** 0596-AD66

**Subject:** Public Comment on Proposed Rule and Draft EIS: Special Areas; Roadless Area Conservation (36 CFR Part 294)

---

### 1. Submitter Interest & Operational Philosophy

I am submitting this comment as a resident living within the Tahoe National Forest. Living directly in a high-risk wildfire landscape gives me a firsthand look at the practical challenge of land management: catastrophic, stand-replacing wildfires represent the single greatest threat to human communities, clean water, and regional biodiversity.

When a severe crown fire incinerates an entire watershed, the resulting canopy loss, soil sterilization, and subsequent monsoonal debris flows destroy coldwater fisheries and fragile native plant communities far more permanently than localized mechanical intervention ever could. Therefore, protecting the landscape and protecting the fisheries requires making **hazardous fuel reduction operationally and economically feasible**.

I urge the Forest Service to avoid the two failing extremes—neither an unconstrained, permanent road network that degrades the land, nor an inflexible "no-roads" mandate that paralyzes active forestry. The Final Environmental Impact Statement (FEIS) should select an action alternative that provides **targeted, low-impact operational access** designed to protect the forest from catastrophic fire while preserving underlying watershed integrity.

---

### 2. Concrete Management Recommendations for the Final Rule

#### A. Enable Operational Feasibility via Temporary, Low-Impact Access

* **The Constraint:** Modern heavy machinery (masticators, feller-bunchers, processing heads, and chip vans) cannot treat overstocked stands without basic physical access. Relying entirely on costly helicopter yarding or hand crews makes large-scale landscape treatments economically unviable.
* **The Solution:** The final rule should explicitly authorize the construction of **temporary access spurs and landings** within Inventoried Roadless Areas (IRAs) specifically for mechanical fuel reduction and forest health restoration.
* **The Guardrail:** To prevent permanent habitat fragmentation, mandate that these temporary routes be legally bound to post-project decommissioning (re-contouring natural drainage, decompaction, and cross-draining) within two years of harvest completion.

#### B. Focus Heavy Mechanical Work on Strategic Defense Zones

* Prioritize road-assisted mechanical thinning along logical fire containment features—such as major ridgetops, natural fuel breaks, infrastructure corridors, and the Wildland-Urban Interface (WUI).
* Treating these strategic anchor points provides wildfire suppression crews safe, defensible space to halt incoming megafires before they enter sensitive, high-elevation core basins.

#### C. Protect Watersheds Through Best Management Practices, Not Paralysis

* Fuel treatments and watershed preservation are complementary goals. The rule should incorporate standard, high-level **Forest Service Water Quality Best Management Practices (BMPs)** rather than broad categorical bans:
* Utilize existing dry season/frozen ground operating windows to prevent soil compaction and rutting.
* Require robust rolling dips and temporary culvert standards on all operational spurs to prevent sediment bleed into nearby streams.
* Restrict ground-based heavy machinery on extreme slopes (greater than 35%) where high soil-shear risks exist, focusing mechanical road access on stable ridges and rolling terrain.

#### D. Prevent Unmanaged Post-Project Use

* The primary driver of human-caused wildfire starts and weed dispersal along forest access routes is unmanaged public vehicle traffic.
* All operational corridors constructed for fuel management must remain strictly closed and gated to unauthorized private motorized vehicles during active operations, followed by immediate physical obliteration once slash processing and haul operations conclude.

---

### 3. Conclusion

We do not have to choose between protecting our aquatic ecosystems and protecting our forests from catastrophic fire. Inaction carries the ultimate ecological cost: incinerated headwaters, debris-choked rivers, and destroyed communities.

Providing forest managers with the flexibility to build temporary, well-engineered, and strictly decommissioned access spurs strikes the exact balance needed—it makes fuel reduction operationally achievable while maintaining the long-term health of our landscape, soils, and coldwater fisheries.

In short: The comment establishes that the current regulatory framework fails to provide operationally feasible access for mechanical fuel reduction in Inventoried Roadless Areas, and requests the final rule authorize temporary, low-impact access spurs with mandatory decommissioning to mitigate wildfire risk while protecting water quality.

Substance score10 / 24A2 · Hard to dismiss — it shows cause and effect
Local knowledge0 / 3
Evidence3 / 3
Legal0 / 3
EA analysis1 / 3
Analytical gap2 / 3
Alternative1 / 3
Request0 / 3
Specific place3 / 3
I support rescinding the 2001 Roadless Rule. I've watched how the broader litigation environment around federal forest management — much of it enabled by the same NEPA-based legal tools that surround roadless designations — gets used by activist groups to delay or kill fuel-reduction work and to roll back non-hiking access, even when local forest managers have already made a reasoned decision. I don't think a single nationwide rule, frozen in place since 2001, is the right way to manage 59 million acres of forest with wildly different fire risk, terrain, and community needs. I'd rather see that judgment made by local and regional forest managers who actually know the ground.

The numbers back this up. The Forest Service's own data shows more than 40% of inventoried roadless areas now carry high or very high wildfire hazard potential, and only about 5% of that acreage has received any hazardous-fuels treatment since 2014 — a huge and growing gap between fire risk and actual management on the ground.[1] Meanwhile, the government's own watchdog has documented for over two decades that appeals and litigation routinely delay hazardous-fuels reduction projects across the National Forest System, sometimes adding years to timelines even when the agency ultimately wins in court.[2] That's not a hypothetical — it's a repeatedly documented pattern, and it's exactly the dynamic I've seen play out: management decisions get made, then get tied up fighting a lawsuit instead of getting fuel on the ground.

The rule itself has never been legally settled ground, either. In 2008, a federal district court in Wyoming ruled the Roadless Rule was promulgated in violation of NEPA and the Wilderness Act and issued a nationwide injunction against it — one of at least 11 major court fights and a Supreme Court petition the rule has generated over 25 years.[3] A rule that has spent a quarter-century bouncing between injunctions, reinstatements, and appeals isn't a stable foundation for either fire management or access planning — it's a standing invitation for the next lawsuit.

I also want to see the Forest Service have real flexibility to expand recreation access, including motorized use, where local managers decide it makes sense — inventoried roadless areas already contain thousands of miles of motorized trail, and the rule's road-construction and reconstruction limits constrain the agency's ability to maintain, reroute, or expand that access over time.[4] And there's already a working precedent for a better path than blanket rescission or blanket preservation: Idaho and Colorado both petitioned for and received their own state-specific roadless rules years ago, tailored to their own land and communities instead of a one-size-fits-all national standard.[5] That's the model I'd want applied more broadly — local control over how roadless land gets managed, not a permanent freeze set by a rule written in 2001.

In short: The comment documents that 40% of inventoried roadless areas have high wildfire hazard with only 5% treated since 2014, and that the 2001 Roadless Rule has been subject to repeated litigation and a 2008 nationwide injunction, establishing a basis for local management flexibility over a national freeze.

Opposing comments — the lower end

The three lowest-scoring opposing exhibits, for a sense of the range.

Substance score6 / 24A0 · Counted, not answered
Local knowledge0 / 3
Evidence0 / 3
Legal0 / 3
EA analysis1 / 3
Analytical gap1 / 3
Alternative1 / 3
Request0 / 3
Specific place3 / 3
Special Areas; Roadless Area Conservation Public Comment,WE OUTNUMBER YOU. Last year, more than 625,000 people from across the United States wrote to the USDA, urging the agency to keep the bipartisan 2001 Roadless Area Conservation Rule, which protects our forests from wildfires and corporate exploitation.Please do not rescind the Roadless Area Conservation Rule, Secretary Rollins. Allowing road construction and logging in these forests will destroy areas crucial to Native Tribes’ spirituality, culture, identity, and survival. These forests provide clean drinking water for more than 60 million U.S. residents and are crucial ecosystems for the wildlife that Tribal Nations depend on. The U.S. federal government has legal obligations to Tribes, including engaging in early and meaningful government-to-government consultation before making decisions about ancestral Tribal homelands. If you take this step to rescind the Roadless Rule, you will violate Tribal sovereignty and therefore the U.S. Constitution. In your own draft environmental impact statement, the federal government incorrectly claims that rescinding the Roadless Rule is a solution to the wildfire crisis. But fires don’t start without cause, and the U.S. Forest Service itself has stated that 9 out of 10 wildfires are caused by people. In fact, fires are four times more likely to start near a road due to cigarettes thrown from car windows, abandoned camp fires, and hot under-carriages of cars igniting tall dry grass.Over the years, many Tribes have spoken out against repealing or making exceptions to the Roadless Rule. Many have done so in the past year, so I’m writing to lift up their voices and urge you to fulfill your obligations to them. The Central Council of the Tlingit and Haida Indian Tribes of Alaska wrote: “The Tongass is more than an ecosystem -- it is our home. It is the foundation of our identity, our culture, and our way of life.” They explained that this step took place “without any prior consultation with our Tribe or other Southeast Alaska tribes” and called on the USDA to “suspend this decision until meaningful consultation is held with tribal nations, as required under federal law and trust obligations.”Gloria Burns, the President of the Ketchikan Indian Community in Alaska said: “We the people of Kichxáan are the Tongass. You cannot separate us from the land… This is an attack on Tribes and our people who depend on the land to eat. The federal government must act and provide us the safeguards we need or leave our home roadless… Without our lungs (the Tongass) we cannot breathe life into our future generations.”The President of the Organized Village of Kake in Alaska explained: “The remaining old growth timber is so important for providing shelter, the berries, and our medicines. It provides shade for our streams to keep them cool so our salmon can return year after year. We are the people of the forest and salmon people. Salmon has sustained us for thousands of years.” His Tribe also hunts deer and moose, which are rebounding after past clear-cut logging.And the President of the Organized Village of Kasaan in Alaska wrote: “The Roadless Rule has worked well for our Tribe and our community by helping to protect customary and traditional uses of our lands and waters, and the fish, wildlife, trees and plants. This helps us honor our ancestors and provide for current and future generations. It would be a grave mistake to roll back these protections. The Roadless Rule must continue to be upheld across the Tongass National Forest.”Please keep the 2001 Roadless Rule. If you want to make any changes, please meaningfully engage in decision-making with sovereign Tribal Nations, in order to honor your constitutional, trust, and treaty obligations to Tribes.Sherrill Futrellsafutrell@ucdavis.edu151 Inner CirDavis, California 95618

In short: The comment documents that the draft environmental impact statement incorrectly claims rescinding the Roadless Rule solves the wildfire crisis, while citing Forest Service data on human-caused fires and asserting that the action violates Tribal sovereignty and consultation obligations under the U.S. Constitution and federal law.

Substance score6 / 24A0 · Counted, not answered
Local knowledge1 / 3
Evidence0 / 3
Legal0 / 3
EA analysis1 / 3
Analytical gap0 / 3
Alternative1 / 3
Request0 / 3
Specific place3 / 3
Dear Forest Service,

I write to urge you to maintain the the 2001 Roadless Area Conservation Rule (2001 Roadless Rule), as it currently exists, keeping the broad prohibitions on road construction, road reconstruction, and timber harvesting that are currently in place. Roadless wilderness is crucial for protecting wildlife, protecting the sources of clean drinking water, and maintaining old growth forest that captures carbon in ways that younger woods cannot and contains complex and irreplaceable biodiversity. Once a road is built in one of these areas, the chances of the area being disturbed in further and detrimental ways is high. But even one road in the midst of a wilderness area does irreparable harm.

As a hiker, river rafter, and camping enthusiast, I am especially concerned with maintaining the pristine wilderness with United States is lucky to have. I’m particularly concerned about and attached to the Shawnee Forest in the southern part of my own home state of Illinois, and also the Kootenai National forest in Idaho and the Olympic National Forest in Washington State, where my family and I have spent many vacations and had life changing wilderness experiences.

Any supposed economic benefit from rescinding the roadless rule would be outweighed by the many costs. The maintenance needed on the 368,000 miles of roads in America’s national forests was one impetus for the Roadless Rule in 2001. Roads in these wilderness areas are extremely expensive to maintain, and the economic analysis that the recession proposal is based on is flawed because projected timber revenues cannot cover the massive costs of building and maintaining new roads in remote forests.

There would also be significant economic impacts to businesses that connect people with wilderness experiences. Wilderness outfitters and guides operating under special use permits would see a great deal of lost revenue due to changes in landscape, recreation quality, and wildlife habitats.

Most important are the non-commodity values that roadless areas provide. These values pertain to the ecological, recreational, passive use, and aesthetic benefits of roadless areas and include things like the conservation of plants, animals, air and water quality, a desire to experience solitude and personal renewal in wild areas, a sense-of-place attachment to a specific area, the desire to leave a legacy of natural areas for future generations to experience and benefit from. Both the economic and non-commodity value of well-functioning ecosystems and biodiversity are tremendous and difficult to accurately measure..

Please maintain the roadless rule and protect our nations old growth forests and back country wilderness. Future generations as well as Americans of today are counting on you.

Sincerely,
Elizabeth Majerus
Urbana, Illinois

In short: The comment establishes specific geographic interest in the Shawnee Forest in Illinois, Kootenai National Forest in Idaho, and Olympic National Forest in Washington, while arguing that the economic analysis supporting rescission of the 2001 Roadless Rule is flawed due to unaccounted road maintenance costs and lost revenue for wilderness outfitters.

Substance score6 / 24A0 · Counted, not answered
Local knowledge0 / 3
Evidence0 / 3
Legal0 / 3
EA analysis1 / 3
Analytical gap1 / 3
Alternative1 / 3
Request0 / 3
Specific place3 / 3
Special Areas; Roadless Area Conservation Public Comment,Last year, more than 625,000 people from across the United States wrote to the USDA, urging the agency to keep the bipartisan 2001 Roadless Area Conservation Rule, which protects our forests from wildfires and corporate exploitation.Please do not rescind the Roadless Area Conservation Rule, Secretary Rollins. Allowing road construction and logging in these forests will destroy areas crucial to Native Tribes’ spirituality, culture, identity, and survival. These forests provide clean drinking water for more than 60 million U.S. residents and are crucial ecosystems for the wildlife that Tribal Nations depend on. The U.S. federal government has legal obligations to Tribes, including engaging in early and meaningful government-to-government consultation before making decisions about ancestral Tribal homelands. If you take this step to rescind the Roadless Rule, you will violate Tribal sovereignty and therefore the U.S. Constitution. In your own draft environmental impact statement, the federal government incorrectly claims that rescinding the Roadless Rule is a solution to the wildfire crisis. But fires don’t start without cause, and the U.S. Forest Service itself has stated that 9 out of 10 wildfires are caused by people. In fact, fires are four times more likely to start near a road due to cigarettes thrown from car windows, abandoned camp fires, and hot under-carriages of cars igniting tall dry grass.Over the years, many Tribes have spoken out against repealing or making exceptions to the Roadless Rule. Many have done so in the past year, so I’m writing to lift up their voices and urge you to fulfill your obligations to them. The Central Council of the Tlingit and Haida Indian Tribes of Alaska wrote: “The Tongass is more than an ecosystem -- it is our home. It is the foundation of our identity, our culture, and our way of life.” They explained that this step took place “without any prior consultation with our Tribe or other Southeast Alaska tribes” and called on the USDA to “suspend this decision until meaningful consultation is held with tribal nations, as required under federal law and trust obligations.”Gloria Burns, the President of the Ketchikan Indian Community in Alaska said: “We the people of Kichxáan are the Tongass. You cannot separate us from the land… This is an attack on Tribes and our people who depend on the land to eat. The federal government must act and provide us the safeguards we need or leave our home roadless… Without our lungs (the Tongass) we cannot breathe life into our future generations.”The President of the Organized Village of Kake in Alaska explained: “The remaining old growth timber is so important for providing shelter, the berries, and our medicines. It provides shade for our streams to keep them cool so our salmon can return year after year. We are the people of the forest and salmon people. Salmon has sustained us for thousands of years.” His Tribe also hunts deer and moose, which are rebounding after past clear-cut logging.And the President of the Organized Village of Kasaan in Alaska wrote: “The Roadless Rule has worked well for our Tribe and our community by helping to protect customary and traditional uses of our lands and waters, and the fish, wildlife, trees and plants. This helps us honor our ancestors and provide for current and future generations. It would be a grave mistake to roll back these protections. The Roadless Rule must continue to be upheld across the Tongass National Forest.”Please keep the 2001 Roadless Rule. If you want to make any changes, please meaningfully engage in decision-making with sovereign Tribal Nations, in order to honor your constitutional, trust, and treaty obligations to Tribes.Mary Kay Garttmeiergarttmeierdesign@gmail.com9200 Redmond Woodinville Rd NE, C408Redmond, Washington 98052

In short: The comment places on the record specific tribal testimony from Alaska (Tlingit and Haida, Ketchikan, Kake, Kasaan) asserting that rescinding the Roadless Rule violates constitutional and trust obligations, and challenges the agency's draft EIS claim that rescission mitigates wildfire risk by citing Forest Service data on human-caused fires and road proximity.

Supporting comments — the lower end

The three lowest-scoring supporting exhibits, for a sense of the range.

Substance score6 / 24A0 · Counted, not answered
Local knowledge1 / 3
Evidence0 / 3
Legal0 / 3
EA analysis1 / 3
Analytical gap1 / 3
Alternative0 / 3
Request2 / 3
Specific place1 / 3
As a Lincoln National Forest Grazing allotment owner, I support the rescission of the 2001 Roadless Area Conservation Rule and offers the following comments:
&bull;<span style='padding-left: 30px'></span>Since 2001, I have witnessed the Roadless Rule&mdash;through centralized management and an extensive history of litigation&mdash;prove ineffective and costly. The rule never produced the expected results.
&bull;<span style='padding-left: 30px'></span>The results from widespread mismanagement as resulted in the loss of millions of acres of overgrown forests to wildfire, disease, and drought.
&bull;<span style='padding-left: 30px'></span>These losses represent billions of dollars in natural resources, including timber that could have been used to build affordable housing to replace homes lost to wildfires and to address the severe housing shortages frequently highlighted in media coverage of homelessness in major urban areas.

I support rescinding the 2001 Roadless Rule because it will decentralize road management and place responsibility for creating, decommissioning, and maintaining roads with individual National Forest Supervisors.
&bull;<span style='padding-left: 30px'></span>Each National Forest is unique, and local supervisors are far better positioned to understand the environmental conditions and management needs of their respective forests than staff located in Washington, D.C., thousands of miles removed from on the ground realities.
&bull;<span style='padding-left: 30px'></span>Local decision making regarding road creation, maintenance, or decommissioning must consider multi use objectives such as recreation, grazing, forest thinning for fire mitigation, and overall forest health. I want to point out that having more trees does not translate into having a healthy forest, especially during droughts in the southwest.
&bull;<span style='padding-left: 30px'></span>Roads that were decommissioned under the Rule rarely received the funding necessary to address erosion issues either before or after decommissioning. Forest Supervisors should work directly with local Soil and Water Conservation Districts to resolve these problems.
&bull;<span style='padding-left: 30px'></span>Each National Forest&rsquo;s Land Management Plan should address road system needs based on local conditions and priorities.
&bull;<span style='padding-left: 30px'></span>Roads identified as Potential Operational Delineation (POD) boundaries must be thinned and upgraded to standards that ensure safe ingress and egress during wildfire events.
&bull;<span style='padding-left: 30px'></span>Individual National Forests must be adequately resourced&mdash;with both funding and personnel&mdash;to maintain existing roads and prevent the creation of illegal user built roads and illegal dumping on Forest Service lands.
&bull;<span style='padding-left: 30px'></span>Individual National Forests should provide clear, detailed information in their Land Management Plans describing how they will manage the road system. Additionally, taking more than seven years to revise a Land Management Plan is unacceptable; for example, the revision of the 1986 Lincoln National Forest Plan, ongoing since 2019, has taken far too long with no clear end in sight.

In short: The comment documents the commenter's support for rescinding the 2001 Roadless Area Conservation Rule, arguing that centralized management has been ineffective and costly, and requesting that road management be decentralized to local National Forest Supervisors with specific requirements for resource allocation, plan revision timelines, and road maintenance standards.

Substance score6 / 24A0 · Counted, not answered
Local knowledge1 / 3
Evidence0 / 3
Legal0 / 3
EA analysis1 / 3
Analytical gap0 / 3
Alternative1 / 3
Request0 / 3
Specific place3 / 3
I saw this posted on Facebook. I could not have expressed it better. This is my opinion.

There&rsquo;s a lot of confusion about the Roadless Rule, so let&rsquo;s start by clearing up one thing: a roadless area isn&rsquo;t the same as Wilderness.

The Roadless Rule covers designated Inventoried Roadless Areas within the National Forest System. Wilderness is a separate designation, protected by Congress. Rescinding the Roadless Rule doesn&rsquo;t touch Wilderness protections. It doesn&rsquo;t mean bulldozers suddenly start rolling into protected Wilderness.

Nor does it throw the forests open to unchecked roads, logging and development. What it actually does is remove a blanket national restriction and hand more discretion back to the forest level, where managers can weigh what&rsquo;s appropriate for the ground in front of them. Forest Plans still apply. Environmental laws still apply. Projects still go through review, and the Forest Service still makes the final call.

Let&rsquo;s also be clear that the Roadless Rule wasn&rsquo;t passed by Congress. It was an administrative policy developed under President Bill Clinton and finalized by his administration in January 2001, just days before he left office. It placed nearly 60 million acres of National Forest land under a blanket national policy restricting road construction, road reconstruction and timber harvest, rather than leaving those decisions primarily to individual forests and their management plans.

Those restrictions also had consequences for forest management. The Forest Service itself acknowledged that restricting road access could make fuel treatments more expensive, make some treatments economically or logistically impractical, and ultimately result in fewer acres being treated. The rule did allow some small diameter thinning and other treatments, but significantly limited timber harvest and the tools managers could use. That doesn&rsquo;t mean the Roadless Rule alone caused today&rsquo;s fuel loads or wildfires. It does mean that in forests already dealing with overcrowding, insects, disease and accumulating fuels, it limited some of the management options available to address them.

The Blue Mountains Forest Plan Revision, covering the Umatilla, Malheur and Wallowa-Whitman National Forests, is a good place to see why these facts matters. The Forest Plan sets the broader framework for managing these forests, but the specific decisions about individual roads are generally made separately, through individual projects or Travel Management.

That opens up a far better conversation than &ldquo;roads everywhere&rdquo; versus &ldquo;roads nowhere.&rdquo;

Some roads matter for wildfire response, restoration, grazing, recreation, public access. Others do more harm than good: they damage watersheds, cost too much to maintain, or simply don&rsquo;t serve a purpose anymore. And the choice isn&rsquo;t always permanently open or permanently closed. Seasonal closures and administrative access can split the difference.

What should drive these decisions is the best available science and the actual conditions on the ground, not emotion or political positioning which is what&rsquo;s happening A LOT right now.

The Hagen Fire in my backyard is a good example of why access belongs in this conversation. It burned into rugged, remote terrain, including the North Fork Umatilla Wilderness, which again is protected on its own, separate from the Roadless Rule. Nothing about rescinding the Roadless Rule changes that.

But the fire still shows what access can mean in the surrounding forest. Crews used Forest Service roads for containment. Multiple spot fires broke out east of Forest Service Road 31, and crews worked through the night to contain them and strengthen the road as a containment line. Officials also pointed to remote terrain and limited access as real challenges during the response. None of this means more roads would have stopped the Hagen Fire. It doesn&rsquo;t mean we should build roads everywhere, either. That&rsquo;s not the point.

The point is that access is one tool among several for managing our forests, fighting fires and doing restoration work, and a blanket national policy shouldn&rsquo;t take that tool off the table everywhere, regardless of the circumstances on the ground.

Let the best available science, local conditions and the needs of each forest help determine what makes sense. Sometimes that means keeping a road. Sometimes it means closing one. But we should be able to have that conversation locally, instead of pretending one answer fits every forest.

In short: The comment documents the specific operational challenges and access limitations encountered during the Hagen Fire response in the Umatilla, Malheur, and Wallowa-Whitman National Forests, specifically citing the use of Forest Service Road 31 for containment and the impact of remote terrain on firefighting efforts.

Substance score6 / 24A0 · Counted, not answered
Local knowledge3 / 3
Evidence0 / 3
Legal0 / 3
EA analysis1 / 3
Analytical gap0 / 3
Alternative1 / 3
Request0 / 3
Specific place1 / 3
I am in favor of rescinding the roadless area regulation. Over the years I have watched the Forest Service close roads and trails to, in essence, create &ldquo;wilderness&rdquo; areas without going through Congress. Areas I used to have access to have been locked up for everyone except the young and those who can afford to hire an outfitter. I witnessed a logging sale that took years to get approved get cancelled (for legitimate reasons). That was the good news. Part of the agreement to have the sale was that roads and trails were to be closed upon completion. Old skid trails were designated as &ldquo;unauthorized.&rdquo; Every one of them was approved as part of a timber sale of past years. This was simply an attempt to make the closure more acceptable. Sort of like undocumented aliens. The roads, skid trails and most of the trails were closed anyway. I even appealed that decision clear to Washington. Needless to say, I lost. I worked for the Forest Service (FS) for 15+ years. It was designed to farm trees like a crop. That is why it was placed in the Dept. of Agriculture. The slogan was/is: :The greatest good for the greatest number of people.&rdquo; This roadless regulation helps prevent the FS from doing its job and limits the people&rsquo;s access to their forest lands.

In short: The comment establishes the commenter's standing based on 15+ years of employment with the Forest Service and personal experience with access restrictions and timber sale cancellations.

Sharing & methodology

These results are meant to be shared.

Please cite us. This analysis is the intellectual property of Roadless.org and Nicholas Holshouser. You are welcome to reproduce it — every reproduction must include this citation:
Roadless.org and Nicholas Holshouser, “2001 Roadless Rule Revision — Substantive Analysis,” https://roadless.org.

How it works. A large language model (an open-weight Qwen 2.5 model) reads each substantive comment and scores it 0–3 on eight dimensions — evidence, legal grounding, engagement with the environmental analysis, analytical gaps, alternatives, specific requests, position, and local knowledge — and extracts quote-accurate verbatim spans for the highest-scoring exhibits. A comment counts as “substantive” when it clears a floor filter — it must show at least one substantive signal (a named entity, a specific citation, a stated analytical deficiency, or first-person testimony), which screens out one-line and purely conclusory submissions before any model scoring.