Comment Analysis · Docket FS-2025-0001

FS-2025-0001-345780

Opposes rescissionA0 noneSubstance 1/24Posted September 12, 2026 On Regulations.gov

Campaign — One letter sent by 10 or more people, copied or lightly reworded. One of 18 submissions in its group; the sender added words of their own. See the letter, its submissions and topics.

Carries the letter's score — A copy of a family's letter; it holds the score and answerability level of the letter it sent.

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. This rating is the one its shared letter earned.

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

  • Forest Management Wildfire
    • “Rather than reduce the risk of wildfires, it will only increase it”
    • “fragmenting or dividing forests into smaller areas via roads could actually directly result in an increased likelihood of extreme wildfires”
    • “The construction of roads would further exacerbate this risk”
  • Scientific Research Evidence
    • “A recent study (doi: 10.1038/s41467-024-53460-6) concludes”
    • “13% of roadless land currently protected experienced wildfires of high or moderate severity between 1984 and 2024”
  • Environmental Protection Biodiversity
    • “cause immense harm to our country”
    • “our beautiful forests, be marred by these potential roads”
    • “remove protections from our public lands”

What it names

Works cited
10.1038/s41467-024-53460-6

The comment

As I type this comment in the 80+ degree heat of yet another record-breaking summer in the formerly-temperate climate of the central coast of California, it's clear that no effort to mitigate the effects of climate change is too small. Rescinding the Roadless Rule would be an enormous step back. Carbon sinks that decrease the impact of the greenhouse effect are shrinking and disappearing as humans continue to develop our environment; the Roadless Rule protects old-growth forest and significant carbon storage. According to the Wilderness Society, wildfires are 4x more likely to start in roaded areas than in roadless forests. Per the Sierra Club, roughly 90% of wildfires start within half a mile of a road. Going through with this decision to repeal the 2001 Roadless Area Conservation Rule will cause immense harm to our country. Rather than reduce the risk of wildfires, it will only increase it. A recent study (doi: 10.1038/s41467-024-53460-6) concludes that fragmenting or dividing forests into smaller areas via roads could actually directly result in an increased likelihood of extreme wildfires. What’s more, 13% of roadless land currently protected experienced wildfires of high or moderate severity between 1984 and 2024 as per the Trump administration’s Federal Register filing. The construction of roads would further exacerbate this risk. Not only would our beautiful forests, which are a source of pride for many Americans, be marred by these potential roads but they would also become much more dangerous to surrounding communities. There are currently two wildfires burning within 50 miles of my city, displacing families and destroying infrastructure. Most of these California fires are caused by careless people going out into the wilderness and camping irresponsibly. Allowing people to access even more forested lands only increases the risk of fire. We need to do everything in our power to keep our forests from burning, both for the climate and for everyone's safety. Also, insurance companies won't insure houses because of the high fire risk in this area. Even when there are no fires occuring, the fire risk negatively affects everyone. I have had to accept an out of state insurance provider to have any coverage of my home at all. A provable increase in the local fire risk (such as would happen if this rule is repealed) would only worsen the situation. I strongly object to this measure to remove protections from our public lands and urge the Department to reconsider.

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