Comment Analysis · Docket FS-2025-0001

FS-2025-0001-299430

Opposes rescissionA1 strongSubstance 10/24Owed an answerPosted September 1, 2026 On Regulations.gov

In short: The comment places on the record specific scientific data and agency EIS findings demonstrating that roadless areas protect drinking water for 25 million Americans and serve as critical habitat for 327 ESA-listed species, while simultaneously increasing wildfire ignition density near roads, thereby challenging the validity of the proposed rule rescission under 36 CFR Part 294.

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 Evidence, 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.
  • Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
  • 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.

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.
  • 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.

Topics

  • Water Quality Quantity
    • “access to safe drinking water that more than 25 million Americans rely on every day”
    • “Roadless areas protect drinking water supplies millions of Americans depend on”
    • “Repealing the Rule risks these sources via added sedimentation and erosion from roads and logging”
    • “Protecting forested watersheds also cuts costs”
  • Wildlife Habitat
    • “Roadless areas are also essential habitat for threatened and endangered species”
    • “Roadless Areas hold over 220 threatened/endangered species”
    • “Rescinding the Rule would open this habitat to new roads, undermining recovery of these species”
    • “Wolves need road densities below about 0.5 km/sq km to persist”
  • Forest Management Wildfire
    • “Building more roadways through dense forested regions that are road free will not achieve the stated goals”
    • “wildfire-ignition density was lowest in designated wilderness areas”
    • “The highest wildfire-ignition density was in lands within 50 m of roads”
    • “scientific studies indicate most fires started in forests are from human beings and occur within 50m of roadways”
  • Environmental Protection Biodiversity
    • “enjoy hiking, birdwatching, and outdoor activities in a rich, thriving ecosystem”
    • “construction and road development will deplete these natural resources”
    • “may affect, likely to adversely affect determination for 327 ESA-listed species”
    • “overturning the Roadless Rule will not help mitigate forest fires”

What it names

National Forests
Helena National ForestLassen National ForestSequoia National Forest
Roadless areas
Rocky Mountain
Law cited
36 CFR Part 294
Works cited
10.1186/s42408-026-00450-210.1371/journal.pwat.0000538

The comment

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

As a son of a UCLA graduate I have enjoyed our family trips to far off wilderness places in the Northwest including Lake Tahoe Basin, the Lassen National Forest, Sequoia National Forest in CA along with Helena National Forest in Montana, to name just a few. These are vital places where we go to enjoy hiking, birdwatching, and outdoor activities in a rich, thriving ecosystem. I am very concerned if the Roadless Rule is repealed, construction and road development will deplete these natural resources along with access to safe drinking water that more than 25 million Americans rely on every day. Building more roadways through dense forested regions that are road free will not achieve the stated goals the USDA is claiming in their August rule change - 36 CFR Part 294 | RIN 0596-AD66. From 1992 to 2024, across 8 US Forest Service regions, wildfire-ignition density was lowest in designated wilderness areas (1.75 fires/1000 hectares). The highest wildfire-ignition density was in lands within 50 m of roads (7.99 fires/1000 hectares). Source: Aplet, G.H., Hartger, P. & Dietz, M.S. Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. fire ecol 22, 8 (2026). https://doi.org/10.1186/s42408-026-00450-2 Roadless areas protect drinking water supplies millions of Americans depend on. Inventoried Roadless Areas protect roughly 131,000 km of rivers nationwide and are the strongest protection mechanism for over 100,000 km of river (Olden et al., 2026). An estimated 25 million Americans get drinking water from these watersheds, with five states (Arizona, California, Colorado, Georgia, North Carolina) each having over a million water customers (Olden et al., 2026). USDA's Draft EIS (2026) notes nearly 5 million people in the Pacific Southwest Region draw drinking water directly from watersheds containing roadless areas, plus over 1 million more in the Intermountain Region and 4 million more across the Northern Rockies, Rocky Mountain, and Intermountain Regions combined. Repealing the Rule risks these sources via added sedimentation and erosion from roads and logging. Protecting forested watersheds also cuts costs: seven U.S. cities avoided hundreds of millions in annual treatment costs this way, and each 10% rise in forest cover cuts treatment/chemical costs by about 20% (Olden et al., 2026). Roadless areas are also essential habitat for threatened and endangered species. The Forest Service's Draft EIS found a "may affect, likely to adversely affect" determination for 327 ESA-listed species and 71 critical habitats under the repeal (USDA Forest Service, 2026). Roadless Areas hold over 220 threatened/endangered species—about 25% of listed/proposed animal species and 13% of listed plant species nationwide (Loucks et al., 2003). The six grizzly bear recovery zones in the northern Rockies include roughly 15,300 sq km of Inventoried Roadless Areas, with nearly 24,750 sq km of contiguous IRAs around the Salmon-Selway Zone alone (Loucks et al., 2003). Wolves need road densities below about 0.5 km/sq km to persist, yet few Middle Atlantic Coastal Forest areas meet that threshold (Heilman et al., 2002). Rescinding the Rule would open this habitat to new roads, undermining recovery of these species. In summary, the roadless rule protects critical watersheds that +25 million Americans rely on for clean drinking water. Furthermore, overturning the Roadless Rule will not help mitigate forest fires though by means of "land management planning," however, scientific studies indicate most fires started in forests are from human beings and occur within 50m of roadways. Source: Aplet, G.H., Hartger, P. & Dietz, M.S. Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. fire ecol 22, 8 (2026). https://doi.org/10.1186/s42408-026-00450-2 Thank you for your time and considering my feedback and the data on key considerations regarding the future of the Roadless Area Conservation Rule. Heilman, G. E., Jr., Strittholt, J. R., Slosser, N. C., & DellaSala, D. A. (2002). Forest fragmentation of the conterminous United States: Assessing forest intactness through road density and spatial characteristics. BioScience, 52(5), 411–422. https://academic.oup.com/bioscience/article/52/5/411/236110 Olden, J. D., Postel, S. L., Dombeck, M. P., Kesting, H., Freeman, P., & Comte, L. (2026). Assessing the value of the U.S. Roadless Rule for people and nature. PLOS Water, 5(7), Article e0000538. https://doi.org/10.1371/journal.pwat.0000538 U.S. Department of Agriculture, Forest Service. (2026, August 19). Draft environmental impact statement—2001 Roadless Rule rescission (Vol. I). Docket No. FS-2025-0001. Loucks, C., Brown, N., Loucks, A., & Cesareo, K. (2003). USDA Forest Service roadless areas: Potential biodiversity conservation reserves. Conservation Ecology, 7(2), Article 5. http://www.consecol.org/vol7/iss2/art5

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