Comment Analysis · Docket FS-2025-0001

FS-2025-0001-225229

Opposes rescissionA3 weakSubstance 10/24Owed an answerPosted August 20, 2026 On Regulations.gov

In short: The comment establishes that the 2001 Roadless Rule is critical for recreation, wildlife habitat, and water quality, and documents that data from OnX indicates roadless areas have a low wildfire ignition rate (3%) compared to the high risk near roads (90% within 1/2 mile), while also noting the $10.8 billion road maintenance backlog.

Scored directly — The comment's whole text was scored on its own.

Scorecard

Each dimension is scored 0–3; the eight sum to the substance score out of 24.

Specific placeNames a specific location — from a region down to an exact creek, trail, road, or map reference.
Local knowledgeDraws on a first-hand connection to the place — visits, sustained activity, occupation, or a professional role.
EA analysisEngages the agency's environmental analysis directly.
Analytical gapIdentifies something the analysis fails to address.
EvidenceBacks claims with specific facts, data, or research.
RequestMakes a specific, actionable request of the agency.
AlternativeProposes a different course of action.
LegalCites statutes, regulations, or legal obligations.

How hard it is to set aside

A3 weak: Substantive, but easier to set aside.

Owed an answer on Evidence.

Standard dismissals it defeats

Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
Outside the scope The agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.

Still open to the agency

Alternative already eliminated The agency says it considered and eliminated the alternative the comment proposes, with a reason. Cannot be defeated from the comment text alone.
Already addressed The agency says its analysis already covers the point. Defeated when the comment cites the law itself: there is no analysis to cite against a statutory claim.
Deferred to a later decision The agency says the point belongs to a later, site-specific decision. Cannot be defeated from the comment text alone.
Not required The agency says the analysis the comment asks for is not required. Cannot be defeated from the comment text alone.
Preference noted The agency notes the comment as a statement of preference and takes no action on it. Cannot be defeated from the comment text alone.
No cause and effect shown The agency says the comment asserts a harm without showing how the action causes it. Defeated when the comment shows the mechanism.
Certified not substantive The agency certifies the comment raises nothing substantive. Defeated when the comment alleges illegality, which is substantive by the definition the certification runs on.

Topics

Recreation Tourism Public Use
- “priceless memories in America's roadless areas through camping, hiking, hunting/fishing”
- “backcountry recreation opportunities across 40 states”
- “Over 17,700 miles of hiking and biking trails, over 1,500 miles of backcountry ski trails”
- “The Roadless Rule has made hunting, fishing, camping, and other recreation better”
Wildlife Habitat
- “impact on recreation, wildlife & wildfires”
- “99% of the Roadless Rule serves as elk habitat”
- “The Tongass National Forest holds 70% of of its Chinook, coho, pink and chum salmon”
- “improving water quality, wildlife habitat”
Forest Management Wildfire
- “data shows the risk of wildfires would exponentially increase”
- “just 3% of wildfires within the last 50 years have ignited in Roadless Rule areas”
- “90% of wildfires have started within 1/2 mile of a road”
- “The rule explicitly allows for wildfire suppression and fuel reduction”
Water Quality Quantity
- “Road construction has many negative impacts for fish habitat through heavy stream-bed sedimentation”
- “Guarantee that no watersheds will be negatively affected by rescission”
- “improving water quality”

What it names

National Forests: Lincoln National Forest Tongass National Forest

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapEvidenceLegal

I strongly oppose the rescinding of the 2001 Roadless Rule. I am a mother to 2 boys who’ve been raised in the National Forests they were born into the ownership of, like all Americans. We have made priceless memories in America’s roadless areas through camping, hiking, hunting/fishing, foraging, and more. I oppose rescinding the Roadless Rule due to its impact on recreation, wildlife & wildfires. Just this past March, I had the pleasure of taking my kids on an adventure into a roadless area of New Mexico and got to pitch a tent with some of the most stunning views of the stars inside of a roadless area in the Lincoln National Forest, not far north of Guadalupe Mountains National Park in Texas. A few months prior, my husband went on an incredible mule deer hunting trip for the opportunity to feed our family (adding money for his license into the tourism economy, as well as conservation funding)and spent hours upon hours each day scouting these amazing animals that use these roadless areas to travel through. When it comes to recreation, our roadless areas provide backcountry recreation opportunities across 40 states. The Roadless Rule notes, “unlike Wilderness, the use of mountain bikes, and other mechanized means of travel is often allowed” as determined by individual forest plans. Over 17,700 miles of hiking and biking trails, over 1,500 miles of backcountry ski trails, and over 3,000 climbing areas lie within these spots. Beyond camping, hiking, skiing, and climbing, these roadless areas also provide ample recreational opportunities for the hunter and angler. In Wyoming, 99% of the Roadless Rule serves as elk habitat; in New Hampshire, 97% serves as black bear habitat; in Arizona, 96% serves as mule deer habitat (OnX Maps). Backcountry access results in 10 times hunter success rates for elk to that of similar public land habitat without Roadless protection. The Tongass National Forest holds 70% of of its Chinook, coho, pink and chum salmon and over 65% of its sockeye and steelhead salmon in its roadless areas. This forest produces more salmon than all the other National Forests combined. Road construction has many negative impacts for fish habitat through heavy stream-bed sedimentation, habitat fragmentation from culverts, and accelerated runoff. Rollins claims rescinding the Roadless Rule would help suppress wildfires in the backcountry, and while it may be true that roads would provide more access to fire fighters, the data shows the risk of wildfires would exponentially increase. Analysis by OnX reveals just 3% of wildfires within the last 50 years have ignited in Roadless Rule areas. The rule explicitly allows for wildfire suppression and fuel reduction including road construction in emergency situations. Studies also have shown that 90% of wildfires have started within 1/2 mile of a road, likely due to increased human activity. The Roadless Rule saves the American Taxpayer money by limiting costly road-building and road maintenance in its remote forests. The National Forest System already carries a $10.8 billion maintenance backlog. The text of the Roadless Rule itself acknowledges the USFS could not maintain its existing road systems. The Roadless Rule has made hunting, fishing, camping, and other recreation better for the last 25 years while simultaneously improving water quality, wildlife habitat, and American’s right to recharge and restore. The Roadless Rule is one of the most popular rules ever implemented in USDA history, with over 95% of the 1.6 million comments in 2001 supporting roadless protections. For all these reasons, I oppose the rescinding of the Roadless Rule, and . I ask that before moving forward, the agency: * Conduct a thorough environmental analysis of roadless areas to assess the impacts of additional road building; * Guarantee that no watersheds will be negatively affected by rescission; * Develop and share a detailed plan for addressing its existing backlog in road maintenance and repairs; * And commit to moving forward with transparency, including a full account of how public comments were considered and concerns addressed. Please protect America’s remaining roadless areas for current and future generations. Savannah S - American mother, angler, hunter, and public land lover