Comment Analysis · Docket FS-2025-0001

FS-2025-0001-341004

Opposes rescissionA0 noneSubstance 7/24Posted September 9, 2026 On Regulations.gov

In short: The comment establishes that the commenter has a direct personal interest in specific roadless areas within the Coronado National Forest, Uinta-Wasatch-Cache NF, and Ocala NF, and documents specific locations where they recreate, including Mount Olympus, Mill Canyon Peak, Butterfly, and Upper Rincon.

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

  • Recreation Tourism Public Use
    • “avid hiker and mountain biker”
    • “lose my favorite places to hike, camp, and mountain bike”
    • “devastated to lose the Mount Olympus, Mill Canyon Peak, Butterfly and Upper Rincon roadless areas”
    • “well-preserved public lands available for recreation”
  • Scientific Research Evidence
    • “best available science suggests that Roadless areas in fact have significantly lower ignition density”
    • “large body of recent research that finds increased fire risk near roads”
    • “ignores the best available science”
    • “Aplet et al., 2026”
  • Wildlife Habitat
    • “important habitat for rare, endangered and special status species”
    • “Mexican spotted owl, ocelots, black bear”
    • “ecosystem services”
  • Water Quality Quantity
    • “essential water resources for cities and towns”
    • “drinking water supply for Salt Lake City”
    • “contamination from road building”

What it names

National Forests
Coronado National ForestOcala National ForestWasatch-Cache National Forest
Roadless areas
Upper Rincon Roadless
Works cited
Balch et al. 2017

The comment

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

I am an Arizona voter, research mathematician and avid hiker and mountain biker. I’m writing with great concern about the possibility of rescinding the Roadless Conservation Rule, RIN 0596-AD66. Throughout my life, I have spent thousands of hours enjoying national forest land, with the most time spent in the Coronado National Forest, Uinta-Wasatch-Cache NF and Ocala NF. All of these areas are important to me personally and it would be a tragedy to open them to road construction and timber harvest. Part of what makes America a great and unique country is well-preserved public lands available for recreation, conservation and ecosystem services. It would be a huge loss to open these lands to roads and logging, and I would personally lose my favorite places to hike, camp, and mountain bike. In particular, I would be devastated to lose the Mount Olympus, Mill Canyon Peak, Butterfly and Upper Rincon roadless areas. All are places where I recreate regularly. In addition to a personal connection to roadless areas, removing these protections poses significant environmental threats. The proposed rule states that removing the Roadless Rule would lower wildfire risk, but the best available science suggests that Roadless areas in fact have significantly lower ignition density than areas within 50 miles of roads (Aplet et al., 2026). There is a large body of recent research that finds increased fire risk near roads and other human influences (Narayanaraj and Wimberly, 2012; Hawbaker et al., 2013; Balch et al., 2017). Based on the available science, I fear that rescinding the Roadless Rule will have the opposite of its intended effects and vastly increase wildfires in America’s National Forests. In addition to fire, roadless areas provide important habitat for rare, endangered and special status species like the Mexican spotted owl, ocelots, black bear and many more. These forests are also essential water resources for cities and towns across the western US. In Utah, the drinking water supply for Salt Lake City and the entire Wasatch Front is at risk with contamination from road building in the High Uintas. Lastly, old growth forests like those in the northwestern US roadless areas are significant carbon sinks (Mildrexler et al., 2020), an essential ecosystem service that keeps humans safe and healthy. In summary, I personally have a lot to lose with the potential withdrawal of the Roadless Rule as I would lose many of my favorite trails in roadless areas. I am also deeply concerned that this proposal ignores the best available science, and would significantly increase fire risks in national forests, as well take away the essential ecosystem services of clean air and water for Americans. References: Aplet, G. H., P. Hartger, and M. S. Dietz. 2026. Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. Fire Ecology 22: 8. Balch, J. K., B. A. Bradley, J. T. Abatzoglou, R. C. Nagy, E. J. Fusco, and A. L. Mahood. 2017. Human-started wildfires expand the fire niche across the United States. Proceedings of the National Academy of Sciences of the United States of America 114: 2946–2951. Hawbaker, T. J., V. C. Radeloff, S. I. Stewart, R. B. Hammer, N. S. Keuler, and M. K. Clayton. 2013. Human and biophysical influences on fire occurrence in the United States. Ecological Applications 23: 565–582. Mildrexler, D. J., L. T. Berner, B. E. Law, R. A. Birdsey, and W. R. Moomaw. 2020. Large trees dominate carbon storage in forests east of the cascade crest in the United States pacific northwest. Frontiers in Forests and Global Change 3: 594274. Narayanaraj, G., and M. C. Wimberly. 2012. Influences of forest roads on the spatial patterns of human- and lightning-caused wildfire ignitions. Applied Geography (Sevenoaks, England) 32: 878–888.

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