Opposes rescissionA0 noneSubstance 3/24Posted August 21, 2026 On Regulations.gov
Scored directly — The comment's whole text was scored on its own.
Scorecard
Each dimension is scored 0–3; the eight sum to the substance score out of 24.
Specific placeNames a specific location — from a region down to an exact creek, trail, road, or map reference.
Local knowledgeDraws on a first-hand connection to the place — visits, sustained activity, occupation, or a professional role.
EA analysisEngages the agency's environmental analysis directly.
Analytical gapIdentifies something the analysis fails to address.
EvidenceBacks claims with specific facts, data, or research.
RequestMakes a specific, actionable request of the agency.
AlternativeProposes a different course of action.
LegalCites statutes, regulations, or legal obligations.
How hard it is to set aside
A0 none: Counted, not answered.
Still open to the agency
Alternative already eliminatedThe agency says it considered and eliminated the alternative the comment proposes, with a reason. Cannot be defeated from the comment text alone.
Already addressedThe 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 decisionThe agency says the point belongs to a later, site-specific decision. Cannot be defeated from the comment text alone.
Misreads the proposalThe agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
Not requiredThe agency says the analysis the comment asks for is not required. Cannot be defeated from the comment text alone.
Preference notedThe 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 shownThe agency says the comment asserts a harm without showing how the action causes it. Defeated when the comment shows the mechanism.
Outside the scopeThe agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.
Certified not substantiveThe agency certifies the comment raises nothing substantive. Defeated when the comment alleges illegality, which is substantive by the definition the certification runs on.
Rescinding the 2001 Roadless Area Conservation Rule would strip protections from tens of millions of acres of undeveloped national forest lands, threatening critical wildlife habitats, clean water sources, and climate stability. Opponents argue that opening these wild areas to logging and roadbuilding causes permanent ecological damage.Ecological and Environmental RisksHabitat Fragmentation: Roads break up large, continuous ecosystems. This disrupts animal migration routes, breeding, and overall wildlife survival.Invasive Species: New roads act as pathways for non-native plants and pests to enter pristine environments.Water Quality: Construction and clear-cutting cause soil erosion, which leads to sediment buildup in streams and damages aquatic life and drinking water supplies.Wildfire and Climate MisconceptionsIncreased Fire Risk: Studies show that areas near roads have a much higher density of human-caused wildfire ignitions, meaning more roads can mean more fires.Ineffective Mitigation: Existing rules already allow for critical fuel reduction and safety treatments without needing to build permanent industrial roads.Carbon Storage: Intact, mature forests act as natural carbon sinks that absorb greenhouse gases, which are released when these forests are cleared or disturbed.Public Value and HeritageLoss of Solitude: Roadless areas provide unique opportunities for quiet recreation like hiking, hunting, fishing, and backcountry climbing.Public Consensus: The original rule was established with overwhelming support from millions of public comments, and public sentiment remains heavily opposed to rolling back these protections. I live in Montana in the Gallatin National Forest that surrounds us. I live near and recreate in the Custer National forest and there are many logging roads already that have been used over the years. To beleive that work can't be done in these areas currently is false. To believe that you have funding for more roads when we have a debt and you continue to take money away from these agencies is a joke. To allow unfettered access by corporations or to sell our lands is criminal at best.