Comment Analysis · Docket FS-2025-0001

FS-2025-0001-260685

Opposes rescissionA0 noneSubstance 3/24Posted 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 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.
Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
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.
Outside the scope The agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.
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

Forest Management Wildfire
- “building roads into roadless areas is likely to result in more fires”
- “human-started wildfires accounted for 84% of all wildfires”
- “forests with higher levels of protection had lower severity values”
- “reduce risk of wildfires”
Environmental Protection Biodiversity
- “maintain the ecosystem for animals, biodiversity”
- “see 'the American Wilderness' in its natural state”
- “protect our United States National Parks from corporate interests”
- “preserve this land for Americans now and in the future”
Recreation Tourism Public Use
- “bring JOY, AWE, and HAPPINESS to Americans”
- “Millions of families have precious memories of family vacations”
- “We do not come for roads, and we do not come to see tree stumps”
- “tour the National Parks”
Water Quality Quantity
- “water supply”
- “protect our United States National Parks”
- “preserve this land for Americans now and in the future”

What it names

Works cited: 10.1002/ecs2.149210.1073/pnas.161739411410.1186/s42408-026-00450-2Balch et al. 2017

Attachments

1 file. Counts as 1 — Counts as one: The attachments enclose no one else's submissions; the comment counts as one.

Own letter

The comment

Hello, I am writing to you to oppose any interference within or around our United States National Parks. This includes for building roads within our National Parks and logging/timber harvesting. We grew up in school in Texas, proudly singing: “This land is my land, this land is your land, from California to the New York island. From the Redwood forest to the Gulf stream waters, this land was made for you and me.” We sang this through Elementary school programs where we received applause from community members and parents alike. As you were reading the lyrics, perhaps you were evening singing them in your head. “Our land”, specifically our United States National Parks bring JOY, AWE, and HAPPINESS to Americans and those that come to America to tour the National Parks to see “the American Wilderness” in its natural state. Millions of families have precious memories of family vacations to visit our National Parks. We do not come for roads, and we do not come to see tree stumps. An argument for increased “forest fires” is not based in fact given MULTIPLE peer reviewed studies negate this narrative. In fact, an “Analysis of 32 years of wildfire data across all eight contiguous-U.S. Forest Service regions found wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads versus just 1.97 fires per 1,000 hectares in inventoried roadless areas—a fourfold difference. Ignition density decreased steadily as distance from roads increased, irrespective of designation. The study concludes that "building roads into roadless areas is likely to result in more fires." (Aplet, Hartger & Dietz, 2026) In addition, we should consider that Humans are the cause for many forest fires – so we cannot blame the ecology of the forests when there are studies that clearly point towards our Human contribution to these fire events. “A national analysis of two decades of wildfire data found that human-started wildfires accounted for 84% of all wildfires, tripled the length of the fire season, and were responsible for nearly half of all area burned. Because roads are the primary vector for human ignitions, the finding directly bears on the wildfire consequences of opening roadless areas to road construction.” Again, building roads through our forests is dangerous as it will cause MORE wildfires. This is in DIRECT DISAGREEMENT with the assertion that building roads would DECREASE wildfires. Clearly – our National Parks will be further debased and harmed by such irresponsible stewardship. (Balch et al, 2017) Arguing that increased biomass would increase the number and severity of forest fires is additionally false. “Comparing fire severity across forests under different protection regimes, the study found forests with higher levels of protection had lower severity values even though they are generally identified as having the highest overall levels of biomass and fuel loading. The result contradicts the claim that protected, intact forests are more dangerous fire risks.” (Bradley, Hanson & DellaSala, 2016) In summary, we the People assert that the Roadless Rule should remain. It is crucial to PROTECT our United States National Parks from corporate interests that would act NOT in the best interests of “Our land.” We should root out and REJECT any claims on our National Parks that are made in the best interest of financial gain and industry “needs.” We ask that our National Parks be protected, preserved, and cared for to maintain the ecosystem for animals, biodiversity, to reduce risk of wildfires, water supply, and to preserve this land for Americans now and in the future. After all, “this land was made for you and me!” References: Aplet, G.H., Hartger, P. & Dietz, M.S. (2026). Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. fire ecol 22, 8. https://doi.org/10.1186/s42408-026-00450-2 Balch, J.K., Bradley, B.A., Abatzoglou, J.T., Nagy, R.C., Fusco, E.J., & Mahood, A.L. (2017). Human-started wildfires expand the fire niche across the United States, Proc. Natl. Acad. Sci. U.S.A. 114 (11) 2946-295. https://doi.org/10.1073/pnas.1617394114. Bradley, C. M., Hanson, C. T., & DellaSala, D. A. (2016). Does Increased Forest Protection Correspond to Higher Fire Severity in Frequent-Fire Forests of the Western United States? Ecosphere, 7, 1-13. https://doi.org/10.1002/ecs2.1492 Sincerely, Deborah A. Lee Belton Texas 76513