Comment Analysis · Docket FS-2025-0001

FS-2025-0001-317441

Opposes rescissionA0 noneSubstance 6/24Posted September 7, 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 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.
  • 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.
  • 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.

Topics

  • Wildlife Habitat
    • “habitat fragmentation”
    • “destroy habitats by paving over them”
    • “logging destroys the habitats of threatened species”
    • “imperative that we do not infringe upon the last habitats free of humans”
  • Climate Carbon Storage
    • “old-growth forests... store massive amounts of carbon dioxide”
    • “vast quantities of carbon dioxide would be released into the atmosphere”
    • “threatens to contribute to climate change by releasing trapped carbon dioxide”
  • Environmental Protection Biodiversity
    • “detrimental to the biodiversity of the United States”
    • “reduces biodiversity by destroying the habitats”
    • “fight for nature conservation”
  • Forest Management Wildfire
    • “vast majority of wildfires start within close proximity to roads”
    • “Creating new roads will only increase the amount of wildfires”
    • “The rescission does not prevent wildfires”

What it names

National Forests
Mendocino National ForestTongass National Forest

The comment

I strongly disagree with the proposed rescission of the 2001 Roadless Area Conservation Rule. Mendocino National Forest is among the most beautiful places in the United States. Alternatives 2 and 3 of the rescission draft remove the protections granted by the Roadless Rule, destroying the beauty of not just Mendocino, but of nature across our country. Repealing the Roadless Rule allows new roads to be constructed through zones previously designated as 'Roadless Areas.' The rescission justifies this under the guise of preventing wildfires by expanding access to hard-to-reach places. One issue with this plan is that the vast majority of wildfires start within close proximity to roads (Aplet Hartger and Dietz 2026). Creating new roads will only increase the amount of wildfires, instead of reducing them, a critical oversight in the rescission. Furthermore, creating roads through roadless areas leads to habitat fragmentation (https://www.environmentalscience.org/roads#habitat-fragmentation). Roads destroy habitats by paving over them with asphalt, but also destroy ecosystems by permanently disrupting wildlife corridors. In an era where climate change and overdevelopment threaten the health and vitality of so many species of animals, it is imperative that we do not infringe upon the last habitats free of humans. Creating new roads through roadless areas will only negatively impact species living in these increasingly threatened habitats. The Roadless Rule also prohibits logging across 45 million acres of national forests. If the Roadless Rule were to be rescinded, logging would be permitted on this land. If logging were to take place in these protected areas, it would be catastrophic: these forests provide habitats for countless species of animals, many of which are endangered or threatened, like grizzly bears, gray wolves, and northern spotted owls. Logging destroys the habitats of threatened species, and would be detrimental to the biodiversity of the United States. Additionally, 9 million of the 45 million acres of forests threatened by the Roadless Rule are old-growth forests. Old growth forests, like much of the Tongass national forest, store massive amounts of carbon dioxide, that otherwise would be released into the atmosphere, contributing to climate change (https://sustainability.stanford.edu/news/shocking-carbon-discovery-swedens-forests). If these forests–irreplaceable because of their age–were to be logged, vast quantities of carbon dioxide would be released into the atmosphere. This undermines the original goal of the rescission, being climate conservation. I believe, along with countless other Americans, that rescinding the 2001 Roadless Rule takes steps in the wrong direction in the fight for nature conservation. The rescission does not prevent wildfires, as even though roads promote access, they also promote wildfires themselves. The rescission also reduces biodiversity by destroying the habitats of threatened and endangered species across the country through permitting logging and road-building. It also jeopardizes the sanctity of irreplaceable old-growth forests, and threatens to contribute to climate change by releasing trapped carbon dioxide into the atmosphere. On a personal level, I want to see the beauty of our national forests be preserved for future generations. I believe that the outcomes of rescinding the Roadless Rule would conflict with my hopes for the future of our forests. For these reasons, I strongly urge you to keep the Roadless Rule as it is, by following Alternative 1 - maintaining the existing Roadless Rule. Thank you.

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