Comment Analysis · Docket FS-2025-0001

FS-2025-0001-356095

Opposes rescissionA0 noneSubstance 7/24Posted September 12, 2026 On Regulations.gov

In short: The comment documents that the rescission of the 2001 Roadless Area Conservation Rule would exacerbate wildfire and flood risks in the Kaibab National Forest and Grand Canyon region, citing the 2025 Dragon Bravo Fire and subsequent Bright Angel Canyon flash floods as evidence of the vulnerability of denuded landscapes.

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

  • Environmental Protection Biodiversity
    • “maintain the nationwide protections currently shielding our roadless backcountry areas from industrial exploitation”
    • “protect the fragile ecosystems surrounding Grand Canyon National Park”
    • “irreversible environmental harms that can never be undone”
    • “Roadless areas serve as a vital buffer zone for wildlife corridors”
  • Water Quality Quantity
    • “prioritize landscape-scale conservation and watershed protection”
    • “devastating flash floods in Bright Angel Canyon”
    • “severe soil erosion into vital municipal and ecological streams”
    • “building roads and cutting timber strips away the vegetative ground cover that slows down torrential monsoonal rains”
  • Forest Management Wildfire
    • “repealing the Roadless Rule actually increases the risk of wildfire starts due to increased human activity”
    • “Industrial logging roads do not stop modern megafires; they invite more points of failure”
    • “catastrophic Dragon Bravo Fire charred nearly 150,000 acres”
    • “Allowing industrial road building and logging under the guise of 'flexibility' will only amplify these systemic vulnerabilities”
  • Recreation Tourism Public Use
    • “visit, hike, and deeply enjoy these protected wild areas”
    • “I want that exact same opportunity to exist for future generations”
    • “Roadless areas serve as a vital buffer zone for wildlife corridors and hikers alike”
    • “These are public lands that should not be for sale to the highest bidder”

What it names

National Forests
Kaibab National Forest

The comment

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

To Whom It May Concern, I strongly oppose the proposal to rescind the 2001 Roadless Area Conservation Rule. I am writing to demand that the U.S. Department of Agriculture and the Forest Service maintain the nationwide protections currently shielding our roadless backcountry areas from industrial exploitation. Over my life, I have had the unique privilege to visit, hike, and deeply enjoy these protected wild areas. I want that exact same opportunity to exist for future generations, but the structural damage being pushed by this administration will create irreversible environmental harms that can never be undone. As someone with a personal stake in the future of northern Arizona, I am submitting this comment to protect the fragile ecosystems surrounding Grand Canyon National Park and the adjacent Kaibab National Forest. The recent compounding tragedies on the North Rim of the Grand Canyon are a stark warning of what happens when we fail to prioritize landscape-scale conservation and watershed protection. In July 2025, the catastrophic Dragon Bravo Fire charred nearly 150,000 acres, destroying the historic Grand Canyon Lodge and leaving a massive, highly vulnerable burn scar across our public lands. This environmental trauma directly precipitated the devastating flash floods in Bright Angel Canyon on August 29. The rapid runoff from the burn scar triggered an influx of mud, rockfalls, and debris that destroyed footbridges, ruptured infrastructure, and tragically claimed human lives - and countless creatures who live in these areas. Despite explicit internal warnings from the park's own trail supervisor—who strongly urged that the North Kaibab Trail remain closed for the 2026 season due to elevated hydrologic risks and unstable trail integrity—the National Park Service and Department of the Interior chose to fully reopen the trail in May. Reopening a primary corridor trail beneath a highly volatile burn scar was a severe oversight in risk management. The agencies should have prioritized structural stabilization and climate-resilient engineering over rushing to clear crowds. Allowing industrial road building and logging under the guise of "flexibility" will only amplify these systemic vulnerabilities. The U.S. Forest Service’s own Draft Environmental Impact Statement (DEIS) reveals that repealing the Roadless Rule actually increases the risk of wildfire starts due to increased human activity and heavy equipment access. Industrial logging roads do not stop modern megafires; they invite more points of failure. Furthermore, building roads and cutting timber strips away the vegetative ground cover that slows down torrential monsoonal rains. As seen in Bright Angel Canyon, denuded landscapes cause immediate, lethal debris flows. Strip-mining the roadless protections from the 1.2 million acres currently protected in Arizona will inevitably lead to severe soil erosion into vital municipal and ecological streams. Stripping protections from the Kaibab National Forest also puts the broader Grand Canyon region at immediate risk for expanded commercial extraction, including uranium mining and commercial timber harvesting. Roadless areas serve as a vital buffer zone for wildlife corridors and hikers alike. The federal government must focus its limited funding and personnel on climate-resilient infrastructure and emergency systems for existing trails, rather than opening untouched backcountry lands to commercial exploitation. The shortsighted policy changes driven by the current administration risk permanently breaking the ecological trust meant for our children. These are public lands that should not be for sale to the highest bidder!!! For these reasons, I urge the agency to select the No Action Alternative and retain the 2001 Roadless Rule in its entirety. Sincerely, Kimberly Carpenter - Hiker, Nature Lover, Tax Payer! Phoenix, AZ 85044

Keep learning. Keep speaking up.The Roadless Rule depends on public engagement. Share what you've learned.

© 2026 roadless.org - Defending America's Last Wild Forests

Privacy Policy|Questions or concerns? noroads@roadless.org|Follow us: @defendroadless