Comment Analysis · Docket FS-2025-0001

FS-2025-0001-260506

Opposes rescissionA2 moderateSubstance 10/24Owed an answerPosted August 23, 2026 On Regulations.gov

In short: The comment documents the commenter's opposition to the rescission of the 2001 Roadless Area Conservation Rule, specifically identifying a gap in the agency's analysis regarding the cumulative loss of roadless character and the contradiction between the wildfire rationale and evidence that road proximity increases ignition density, while requesting specific analyses and the retention of the rule with targeted exceptions.

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

A2 moderate: Hard to dismiss — it shows cause and effect.

Owed an answer on Analytical gap, Alternative.

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.
No cause and effect shown The agency says the comment asserts a harm without showing how the action causes it. Defeated when the comment shows the mechanism.
Outside the scope The agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.

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.
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
- “regularly camp and hike in National Forests”
- “preserving some large areas without roads is also an important public use”
- “Roadless areas provide an experience that cannot be recreated”
- “quiet, remoteness, intact habitat”
Forest Management Wildfire
- “wildfire ignitions occur at substantially greater density near roads”
- “opening currently roadless areas to additional road construction would reduce wildfire risk”
- “stated wildfire rationale does not justify eliminating protections nationwide”
- “targeted approach, not complete rescission”
Environmental Protection Biodiversity
- “intact forest ecosystem”
- “intact habitat”
- “cumulative loss of roadless character”
- “restoring genuine roadlessness is much more difficult”
Governance Policy Process
- “replacing a nationwide roadless protection with individual project decisions”
- “adopt narrowly tailored additional exceptions where necessary”
- “Analyze the cumulative loss of roadless character”
- “preserves the general prohibition on new roads”

What it names

National Forests: Black Hills National Forest Sawtooth National Forest

The comment

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

I oppose rescission of the 2001 Roadless Area Conservation Rule. My husband and I regularly camp and hike in National Forests around the country. We enjoyed the Sawtooth National Forest this May and have returned to the Black Hills National Forest multiple times. The Black Hills is where I began paying much closer attention to wildflowers and the smaller details of an intact forest ecosystem. I have also backpacked extensively in California forests. I am not opposed to logging or active forest management. We frequently camp in areas where timber has been harvested, and I recognize that National Forests are working forests with multiple uses. But preserving some large areas without roads is also an important public use of these lands. Roadless areas provide an experience that cannot be recreated simply by closing a road after it is built. Walking into a landscape without roads provides quiet, remoteness, intact habitat, and the opportunity to experience nature with relatively little human alteration. For me, that also has a spiritual value. Seeing an intact forest—its trees, wildflowers, wildlife, streams, and terrain—is one of the few ways we can still see, as closely as possible, what God created rather than a landscape redesigned for human purposes. I am particularly concerned that the stated wildfire rationale does not justify eliminating protections nationwide. Research cited during this rulemaking indicates that wildfire ignitions occur at substantially greater density near roads than within inventoried roadless areas. The Forest Service should address that evidence and explain why opening currently roadless areas to additional road construction would reduce wildfire risk rather than potentially increase human-caused ignitions. The agency should also consider the cumulative effect of replacing a nationwide roadless protection with individual project decisions. A particular road may appear minor when considered separately, but repeated decisions over many years could gradually eliminate the very characteristic the Rule was intended to preserve. Once roads penetrate an intact landscape, restoring genuine roadlessness is much more difficult than allowing harvested trees to regrow. I recognize that some areas may require mechanical treatment, wildfire mitigation, or other active management. But that supports a targeted approach, not complete rescission. If existing exceptions are inadequate, the Forest Service should identify the specific management problems and adopt narrowly tailored additional exceptions where necessary. I therefore ask the Forest Service to retain the Roadless Rule and, before making any final decision, to: 1. **Analyze the cumulative loss of roadless character** that could result from replacing nationwide protection with individual forest-level and project-level road decisions. 2. **Address the evidence concerning wildfire ignitions near roads** and explain why additional road construction into currently roadless areas would advance the stated wildfire-reduction objective. 3. **Evaluate roadlessness as a distinct recreational, ecological, and experiential resource**, including quiet, remoteness, intact habitat, opportunities to observe natural systems, and the ability to travel through large undeveloped landscapes. 4. **Explain why targeted measures are insufficient**, including existing exceptions, additional narrowly tailored exceptions, or geographically limited treatment of areas presenting demonstrated wildfire or forest-health risks. 5. **Consider an alternative that preserves the general prohibition on new roads** while allowing necessary management in specifically identified high-risk areas. Our National Forests have room for logging, active management, roads, motorized recreation, and developed recreation. They should also preserve some places where the road ends.