Comment Analysis · Docket FS-2025-0001

FS-2025-0001-299130

Opposes rescissionA1 strongSubstance 6/24Owed an answerPosted September 1, 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

A1 strong: Must be answered — it names the law.

Owed an answer on Analytical gap, Legal.

Standard dismissals it defeats

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.
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.

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.
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.
Outside the scope The agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.

Topics

Environmental Protection Biodiversity
- “biodiversity loss and habitat degradation continue to threaten wildlife”
- “habitat fragmentation and ecosystem impacts can persist for decades”
- “strengthening protections for roadless areas rather than eliminating them”
Forest Management Wildfire
- “wildfires are approximately four times more likely to ignite near roads”
- “Opening intact backcountry forests to additional road construction is not a sound wildfire prevention strategy”
- “Roads increase human access and human-caused ignition sources”
Water Quality Quantity
- “Roadless areas protect... clean water”
- “construction of roads always alters drainage”
- “contributes to erosion and lowered water quality”
Recreation Tourism Public Use
- “tradeoffs with opportunities for quiet, remote and self-reliant recreation”
- “losses in economic benefit to recreationists”
- “increase user conflicts and result in lost economic benefits”

What it names

Law cited: 5 U.S.C. 553 7 CFR 1.28 Executive Order 14192
Works cited: 10.1186/s42408-026-00450-2

The comment

The Roadless Rule was intended to protect wilderness that had never had human contact. And although some of the areas the rule covers have had human contact, we should not continue to ‘touch it’, and instead use these areas for further research on how wilderness can protect us! Roadless areas protect wildlife, clean water, climate resilience, and ecological connectivity, and provide a baseline for scientific research and data collection. Once roads are built, habitat fragmentation and ecosystem impacts can persist for decades. At a time when biodiversity loss and habitat degradation continue to threaten wildlife across the United States, the Forest Service should be strengthening protections for roadless areas rather than eliminating them. The intent of this proposed action is to reduce regulatory burden and return decision-making for the management of inventoried roadless areas to the land management planning process at the individual national forest level, informed by Tribes, State, and local communities (Executive Order 14192, Unleashing Prosperity Through Deregulation). While I am a strong proponent of subsidiarity, the pressures seen by state and local governments will compel short-term decisions and sacrifice the long-term protections intended by the original rule. The USDA will tell you that rescission of the national-level prohibitions provides responsible officials with flexibility to better guide management of National Forest System lands and respond to changing local resource conditions. The Forest and Rangeland Renewable Resources Planning Act of 1974, as amended by the National Forest Management Act of 1976, and the associated land management planning processes and plans are the appropriate and effective mechanisms to guide sustainable, integrated management of the resources within the plan areas in the context of the broader landscape, giving due consideration to the relative values of the various resources in particular areas. However, after rescindment, any State, Tribe, or other interested entity seeking to establish roadless management provisions tailored to specific geographic or resource conditions must submit a petition for rulemaking under the Administrative Procedure Act (5 U.S.C. 553(e)) and USDA regulations at 7 CFR 1.28, which will be a costly and onerous process, which likely will not result in any change to the inventoried roadless area provisions. The USDA will also tell you that rescinding the Roadless Rule could help address wildfire risk, but recent peer-reviewed research suggests otherwise. A 2026 study found that wildfires are approximately four times more likely to ignite near roads than in roadless areas (R.T., et al. (2026). Human access and wildfire ignition patterns in roaded and roadless forests. Fire Ecology, 22. https://link.springer.com/article/10.1186/s42408-026-00450-2). Roads increase human access and human-caused ignition sources, including unattended campfires, discarded cigarettes, and vehicle-related sparks. Opening intact backcountry forests to additional road construction is not a sound wildfire prevention strategy. The Environmental Impact statement estimates rescindment will result in permanent road construction in 45% of current Roadless Rule Land (RRL) (18.2M acres), and temporary road construction in 28% additional RRL (11.3M acres); providing more human access and removing the forest that would mitigate the climate change that the Forest Service blames for increased wildfire risk. The construction of roads always alters drainage and often contributes to erosion and lowered water quality. Through the Environmental Impact Statement, the USDA will claim that rescindment will result in $5.2 to $11.4 million per year in revenue to the Treasury and Forest Service and $4.6 to $10.6 million per year in revenue to the timber industry, but it also predicts losses in economic benefit to recreationists associated with the operable areas could be an estimated $6.1 million annually. Temporary impacts to recreation and related industry opportunities, include noise, visible infrastructure, and temporary closures. In the longer term, developed and road-based recreation could expand through development of some new permanent roads, though this expansion is uncertain and anticipated to be limited due to land management plans, budget, and resources. This expansion could increase road-based recreation and accessibility improvements but would result in tradeoffs with opportunities for quiet, remote and self-reliant recreation and may increase user conflicts and result in lost economic benefits. Thank you for your consideration.