Opposes rescissionA0 noneSubstance 5/24Posted August 25, 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.
“pristine, old-growth, and mature biodiverse forests”
“permanently alters their ecological integrity”
The comment
Dear U.S. Forest Service and Department of Agriculture:
I am writing to express my strong opposition to the proposed rule to rescind the 2001 Roadless Area Conservation Rule. I urge the agency to maintain the existing protections that safeguard nearly 45 million acres of intact national forest land. Stripping these protections will cause irreversible ecological degradation.
I oppose this decision for the following critical reasons:
Destruction of Forest Ecosystems: Rescinding the rule opens pristine, old-growth, and mature biodiverse forests to commercial logging and industrial extraction. These unfragmented ecosystems are essential climate buffers and carbon sinks. Replacing them with industrial infrastructure permanently alters their ecological integrity.
Destruction of Wildlife Habitat: Roadless areas provide essential, contiguous habitat for more than 1,400 sensitive, threatened, or endangered species. Constructing roads and introducing heavy machinery will fragment corridors, block migration routes, and isolate wildlife populations that depend on remote habitats to survive.
Increased Wildfire Risk via Human Access: While this proposal is framed as a wildfire management strategy, the Forest Service’s own data shows that the vast majority of wildfires are human-caused and start near existing roads. Expanding road networks into currently roadless areas increases human access, which directly escalates the risk of human-caused ignitions.
Severe Soil Erosion: Tree removal and heavy equipment operation compact forest soils and eliminate root structures. This lack of stability will result in severe soil erosion, particularly on steep slopes, permanently degrading the landscape and preventing healthy forest regeneration.Pollution of Watersheds: Forests act as natural water filtration networks. Increased erosion from logging and runoff from new dirt and gravel roads will deposit heavy sediment into pristine headwaters. This pollution directly threatens clean drinking water supplies for downstream communities and destroys critical aquatic habitats for fish and amphibians.
The 2001 Roadless Rule already allows forest managers to implement fuel management projects to mitigate fire risks near communities without building permanent roads. Developing an additional network of roads—when our National Forest System alreadyaces a massive road maintenance backlog—is ecologically and financially irresponsible.For the sake of our water, wildlife, and future generations, I ask that you withdraw this proposal and leave the 2001 Roadless Rule fully intact.
Sincerely,
US Citizen with Constitutional ownership of public lands and National Parks;
Roger Parks
104 Edwards Cir.
Simpsonville, SC 29681