Comment Analysis · Docket FS-2025-0001

FS-2025-0001-266996

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

In short: The comment places on the record specific scientific evidence and economic data demonstrating that road construction in the Green Mountain and Olympic National Forests would increase wildfire risk, degrade water quality, and destroy wildlife habitat, while simultaneously highlighting the agency's inability to maintain its existing road system due to a $15.6 billion deferred 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

Wildlife Habitat
- “species composition of inventoried roadless country differs measurably”
- “destroy wildlife habitat”
- “77% of roadless areas have potential to conserve threatened & endangered species”
- “migratory... wouldn't have the successes here with so much interference”
Forest Management Wildfire
- “road-building doesn't necessarily reduce wildfire risks”
- “human-caused ignitions were concentrated near roads”
- “Road building and vegetation management reshape fire regimes”
- “Roads across our protected areas will significantly increase these incidences”
Water Quality Quantity
- “threaten drinking water sources”
- “roaded landscapes correlate with higher sediment loads”
- “roadless areas act as refugia for salmonids and freshwater biodiversity”
Climate Carbon Storage
- “worsen climate change”
- “76% of MOG on federal lands (storing 10.64 Gt CO2e) is vulnerable to logging”
- “Paris Agreement compliance and 30x30 targets”

What it names

National Forests: Olympic National Forest
Roadless areas: Green Mountain
Works cited: 10.1016/j.apgeog.2011.09.004

The comment

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

Dear Brooke L. Rollins, What I, as a wildlife observer, am in a position to attest — and what the agency's own monitoring data confirms — is that the species composition of inventoried roadless country differs measurably from that of proximate roaded country, and the 2001 Rule is what has preserved that distinction. The roadless areas around my home, which are many, are considered our backyards here. True pathways into nature. No heavy equipment and roads ruining the environment. No future high costs of more roads to maintain, while facing consistently reduced annual budgets. We have to do EVERYTHING to protect what we have. There's no UNDO button. Among many days in these forests, one has stayed with me. As a birder, I've seen so many firsts for my life list. And because many of these are migratory, they wouldn't have the successes here with so much interference from roads, equipment, car noise, auto/animal accidents, and more. The Department is urged to find, on the basis of this and similar testimony, that the burden of justification for rescission has not been met and that the 2001 Roadless Area Conservation Rule should remain in effect. Road building and vegetation management reshape fire regimes by changing ignition sources, fuel loads, and landscape-scale fire behavior. Most ignitions near roads are human-caused. The same study found that human-caused ignitions were concentrated near roads, near the wildland-urban interface, and in high-road-density areas. Lightning-caused ignitions, by contrast, were concentrated away from roads and in lower-density areas. The further from a road, the fewer human-caused fires (Narayanaraj & Wimberly 2012; Aplet et al. 2026). — Ganapathy Narayanaraj | Michael C. Wimberly, 2012 · Applied Geography (https://doi.org/10.1016/j.apgeog.2011.09.004) Rescinding the Roadless Rule would open the Green Mountain, Olympic National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. It's been proven with studies that road-building doesn't necessarily reduce wildfire risks. One big reason is man is more times than not the cause of wildfires. Roads across our protected areas will significantly increase these incidences. If there's a natural cause, such as lightning, that's going to happen regardless. The Federal Register Notice initiating the rescission states the goal explicitly: to "facilitate domestic production" of "timber, energy and mineral production... to the maximum possible extent." The proposal is being advanced under Executive Orders 14192 (deregulation), 14225 (timber expansion), and 14154 (energy unleashing), and follows other administrative actions calling for a dramatic increase in logging and oil and gas drilling on federal lands. An increase in these industrial activities would worsen climate change, destroy recreation areas, put the lands at greater risk of wildfire, destroy wildlife habitat, and threaten drinking water sources. Building more roads in national forests would be a drain on taxpayers. Even with the Roadless Rule in place, the Forest Service already has a 380,000-mile road system—twice as long as the U.S. highway system—crisscrossing national forests. The agency cannot afford to maintain it: the deferred-maintenance road backlog was estimated at $8.4 billion in the 2001 Final Environmental Impact Statement and is roughly $15.6 billion in today's dollars. The Government Accountability Office has repeatedly flagged Forest Service deferred maintenance as one of the largest in the federal government, and the backlog has never dropped below $5 billion. Adding new roads to inventoried roadless areas would only deepen that hole. “National-scale analysis found 77% of roadless areas have potential to conserve threatened & endangered species, with strong concordance with grizzly recovery zones. — Research - Biodiversity Conservation” “National monitoring analysis using ~20 years of data found forests in roadless areas burned at similar frequencies as roaded areas. Claims that road prohibitions harm forest health are not supported by evidence. — Research - Fire Safety” “Literature synthesis shows roaded landscapes correlate with higher sediment loads, while roadless areas act as refugia for salmonids and freshwater biodiversity. — Research - Water Quality” “Maps mature and old-growth (MOG) forests across the conterminous U.S. using LiDAR-derived structural metrics. Finds 76% of MOG on federal lands (storing 10.64 Gt CO2e) is vulnerable to logging. Recommends elevating the conservation status of Inventoried Roadless Areas as a key step toward Paris Agreement compliance and 30x30 targets. — Research - Old-Growth Climate Solution” Kind regards, CommentID: RLC-20260824-4G8ORL