Opposes rescissionA0 noneSubstance 5/24Posted August 23, 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.
This comment is informed by direct experience with the following account.
These areas must remain intact for future generations to enjoy the untouched beauty of our States. The unique feelings evoked by these places cannot be replicated elsewhere. Reducing the protections granted to these areas is selfish and unnecessary.
The Department is urged, both legally and policy-wise, to retain the Rule and reject the current proposal.
As someone who seeks out public lands, I want the Department to understand that the 2001 Rule is not regulatory excess; it preserves the appeal of certain places.
Regarding the Tuolumne River in the Stanislaus National Forest, California:
A study in Idaho found that 70% of sediment deposition from roads occurred in the first year after construction, with significant amounts traveling less than 100 meters from the source (Ketcheson and Megahan, 1996). This highlights the environmental impact of road construction.
The Roadless Rule remains one of America's most supported conservation measures. Prior to its 2001 enactment, over 600 public hearings were held, and 1.6 million Americans expressed their support for protecting these forestlands. The USDA's rescission proposal in late 2025 garnered around 600,000 comments, with more than 99.8% opposing the roll back. A February 2026 national poll by Pew Charitable Trusts showed that 76% of likely voters support the Rule, with bipartisan backing from 71% of Republicans and 80% of both Democrats and independents. Additionally, over 100 members of Congress have co-sponsored the Roadless Area Conservation Act of 2025 (S.2042 / H.R.3930) to ensure the Rule cannot be altered without Congressional approval.
Building more roads in national forests would impose a burden on taxpayers. The Forest Service already has a 380,000-mile road system—twice the length of the U.S. highway system—yet struggles to maintain it. The estimated deferred-maintenance road backlog was about $15.6 billion in today's dollars, as reported by the Government Accountability Office, highlighting the agency’s ongoing maintenance challenges. Adding new roads to roadless areas would worsen this financial strain.
U.S. National Forests serve as vital headwaters for many of our major rivers and are key for municipal water supply nationwide. According to DellaSala (2011), national forests provide drinking water to 124 million people across 33 states, with about one-third of all national-forest runoff coming from inventoried roadless areas. Roads are notorious for causing water pollution, with erosion from logging roads significantly higher than from undisturbed forest areas. The protections afforded by the 2001 Roadless Rule are crucial for maintaining safe drinking water for communities, including major cities like Los Angeles, Portland, Denver, and Atlanta.
Forest Service Chief Tom Schultz previously testified about 24.5 million acres of inventoried roadless areas being near the Wildland-Urban Interface (WUI), but a GIS analysis by The Wilderness Society revealed this figure is inflated by nearly nine times—realistically, just 2.8 million acres are close to the WUI. Less than 5% of inventoried roadless area acreage is actually in proximity to the WUI, contrary to Schultz's claims. The administration has access to 23.3 million acres of non-roadless forest land near the WUI for fuel reduction, negating the need to encroach on roadless areas.
Though proponents of rolling back the Roadless Rule argue for wildfire management, evidence suggests otherwise. A 2026 study in Fire Ecology analyzed 32 years of wildfire data and found that wildfire-ignition density was higher near roads.
In conclusion, retaining the 2001 Roadless Rule is essential for conservation, safeguarding drinking water, and protecting our natural heritage for future generations.