Opposes rescissionA0 noneSubstance 6/24Posted August 28, 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.
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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.
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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.
I oppose this proposal to rescind the 2001 Roadless Area Conservation Rule and open millions of acres of national forest to road construction and logging. My reasons:
--Wildlife habitat fragmentation. Roads are one of the most disruptive forces in forest ecosystems — they split animal populations, block migration and access to food and mates, and create corridors for poaching and disturbance. Grizzly bears have historically suffered most near roads not from vehicle strikes but from the human activity roads bring into their habitat.
--The wildfire-risk justification is contradicted by the evidence. The agency argues this rule change will reduce wildfire risk, but the data points the opposite direction. A 2025 Wilderness Society analysis found that wildfire density is lowest in wilderness and protected forest areas, and highest in the areas near roads. This isn't incidental: roads themselves are a documented wildfire cause. Expanding road networks into currently roadless forest is more likely to increase ignition risk than reduce it.
--Watershed and soil damage. Logging roads chronically erode, dumping sediment into streams that harms fish spawning and water quality. Reporting in Smithsonian magazine (Ben Goldfarb, "The Case for Destroying Old Forest Roads," March 2024) notes that, in 1995, storm-triggered landslides tied to old logging roads in Idaho's Nez Perce-Clearwater National Forest produced more than 900 landslides that buried streams under more than 50,000 dump trucks' worth of sediment — a preview of the kind of long-term damage new road construction risks recreating elsewhere.
For these reasons, I urge the Forest Service to withdraw this proposal and retain the Roadless Rule's protections.