Comment Analysis · Docket FS-2025-0001

FS-2025-0001-306729

Opposes rescissionA3 weakSubstance 9/24Owed an answerPosted September 3, 2026 On Regulations.gov

In short: The comment places on the record specific peer-reviewed evidence that roadless areas are not a barrier to wildfire prevention and provide critical habitat for species of conservation concern, specifically citing Bighorn National Forest, Colorado, and the Tongass National Forest in Alaska as locations where the Roadless Rule protects these resources.

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
- “encounters with moose and other native wildlife”
- “roadless areas provide a larger proportion of suitable habitat for multiple wildlife SCCs”
- “habitats would be fractured and permanently degraded by the removal of the Roadless Rule”
- “imperil the habitats and wild animals”
Forest Management Wildfire
- “roadless areas have a neutral effect on wildfire incidence”
- “fuel management activities in roadless areas have actually been more numerous”
- “no evidence that roadless areas are a barrier to wildfire prevention”
- “placing more forest and by extension more citizens at risk”
Recreation Tourism Public Use
- “opportunities I have for backpacking and wildlife watching”
- “peace and solitude we enjoyed there”
- “ardent backpacker and wildlife watcher”
- “American landscape”
Scientific Research Evidence
- “meaningful body of research including research conducted by the Forest Service itself”
- “Environmental Research Letters article Long-term forest health implications of roadlessness”
- “2021 article in the scientific journal Global Ecology and Conservation”
- “not supported by nearly twenty years of monitoring data”

What it names

National Forests: Bighorn National Forest
Works cited: 10.1016/j.gecco.2021.e01943Healey 2020Healey 2020

The comment

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

Dear USFS, As a Western resident and avid outdoorsman, I wish to express my strong support for the no action alternative and the 2001 Roadless Area Conservation Rule. The Roadless Area Conservation Rule is of extreme relevance to my day-to-day quality of life, from the air I breathe to the opportunities I have for backpacking and wildlife watching activities that are integral to my physical, mental, and spiritual wellbeing. One of my most precious shared experiences with my fiancée, now my wife, was on a trip to Bighorn National Forest, much of which is inventoried roadless area (IRA). The peace and solitude we enjoyed there, along with our encounters with moose and other native wildlife, made clear to me that roadless areas are themselves a crucial resource, one that merits careful stewardship and long-sighted conservation. Living in Colorado, I am well acquainted with the health hazards posed by wildfire smoke, which is part of why I urge USFS to retain the Roadless Rule. There is a meaningful body of research including research conducted by the Forest Service itself which shows that, at worst, roadless areas have a neutral effect on wildfire incidence. I am referring here to the Environmental Research Letters article Long-term forest health implications of roadlessness, authored by a Forest Service researcher in 2020 (https://doi.org/10.1088/1748-9326/aba031). According to this peer-reviewed paper, Agency management records show that a lack of roads has not stopped fire prevention measures; fuel management activities in roadless areas have actually been more numerous on a per-square kilometer basis than elsewhere in the National Forest System. Given that inventoried roadless areas already undergo a higher degree of fuel management than other portions of the National Forest System, I question why the Forest Service is choosing to focus on inventoried roadless areas as part of its efforts to reduce wildfires wouldnt it be more effective to focus on areas that are relatively under-managed? Furthermore, the Environmental Research Letters article concludes that Speculation that eliminating road prohibitions would improve forest health is not supported by nearly twenty years of monitoring data. In other words, the Forest Service's own researchers have found no evidence that roadless areas are a barrier to wildfire prevention. Rather, by rolling back the Roadless Rule, USFS would be placing more forest and by extension more citizens at risk than ever before. In addition to my home state of Colorado, I am an avid wildlife watcher in the Western states of Wyoming, Utah, New Mexico, Arizona, Nevada, and California all states with vulnerable wildlife species and sizable inventoried roadless areas. A 2021 article in the scientific journal Global Ecology and Conservation (https://doi.org/10.1016/j.gecco.2021.e01943) found that inventoried roadless areas provide a larger proportion of suitable habitat for multiple wildlife SCCs [species of conservation concern] than non-IRA CONUS [contiguous United States] lands. In other words, roadless areas provide outsize benefits to vulnerable wildlife species - species whose habitats would be fractured and permanently degraded by the removal of the Roadless Rule. The wild species that populate the Wests inventoried roadless areas are not just part of the scenery they are an integral part of our countrys natural heritage. As a volunteer with the Bird Conservancy of the Rockies Bald Eagle Watch program and an avid wolf- and bear-watcher in the forests of Wyoming and Montana, I have seen firsthand the difficulties that roads and fragmented habitats pose to some of our countrys most iconic animals. I therefore urge USFS to consider how recission of the Roadless Rule would impact American wildlife, including bald eagles, bears, and wolvesnot only here in the lower forty-eight, but also in the Tongass of Alaska, whose unique temperate rainforest ecosystem (the largest remaining in the world) is home to the Alexander Archipelago wolf and the worlds highest density of nesting bald eagles. As a resident of the West and an ardent backpacker and wildlife watcher, I urge USFS to take the "no action" alternative and to uphold the Roadless Area Conservation Rule. The individualism, dynamism, and optimism of the American people are inseparable from are in many ways a product of the American landscape. As such, I urge USFS to uphold the Roadless Rule, as intensified road construction in our national forests would not only fail to make us safer from wildfires, it would also imperil the habitats and wild animals that give form to the American ideal of freedom. Sincerely, Collin Van Son Colorado resident