Opposes rescissionA0 noneSubstance 4/24Posted September 12, 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.
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How hard it is to set aside
A0 none: Counted, not answered.
Still open to the agency
Alternative already eliminatedThe agency says it considered and eliminated the alternative the comment proposes, with a reason. Cannot be defeated from the comment text alone.
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Misreads the proposalThe agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
Not requiredThe agency says the analysis the comment asks for is not required. Cannot be defeated from the comment text alone.
Preference notedThe 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 shownThe agency says the comment asserts a harm without showing how the action causes it. Defeated when the comment shows the mechanism.
Outside the scopeThe agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.
Certified not substantiveThe agency certifies the comment raises nothing substantive. Defeated when the comment alleges illegality, which is substantive by the definition the certification runs on.
This year, I personally had a death in our family, and it was hastened by wildfire smoke directly. I watched when the smoke rolled in, my loved one declined dramatically more quickly. Even when the fires don't reach our homes, we are harmed. And, even when the smoke doesn't reach our homes, we are harmed. We need to protect our forests, for many reasons. We need to preserve unfragmented habitat, for humans, for animals, for climate change, for biodiversity, and for so, so, many innumerable reasons. We need to reduce wildfires. There are many good actions we could be taking towards those ends and this isn't the way forward. ( https://doi.org/10.1016/j.ijdrr.2018.09.016 ) If we want to reduce wildfires we should be putting our focus on climate change generally, and chipping away at some of our best carbon sinks isn't how we do that. We can't afford the long term carbon losses from careless fragmentation and unplanned wildfires. ( https://doi.org/10.1007/s44246-025-00206-8 ) Again, this just isn't the way forward.
Fire interacts with fragmentation in ways that are detrimental to biodiversity. When fire and fragmentation act together they can cause local extinctions, even when their separate effects are neutral. Then feedback loops can happen that completely collapse the present ecosystem, when otherwise that wouldn't occur. ( https://doi.org/10.1111/brv.12687 ) Forest fragmentation has also been shown to directly increase forest mortality by increasing stress, damaging habitats, and heightening vulnerability to disturbances, like, for example, wildfires. ( https://doi.org/10.3390/f16040565 ) During the linked systematic review, out of 119 articles, 107 research articles reported a negative effect of forest fragmentation, thereby indicating that an increase in forest fragmentation leads to an increase in forest mortality. Eleven articles reported positive effects of forest fragmentation, comprising often rare, localized, and context-specific scenarios where increased fragmentation led to a reduction in forest mortality. A large percentage of these studies were on temperate forests, in America. At best, you could say we need more research on the subject in some specific situations and, perhaps, more long term data and studies. But the current data we have does not support fragmenting our forests by building these roads.
Repealing the 2001 Roadless Area Conservation Rule is intensely harmful to America and all Americans, as it will actually increase wildfires. See this study, (doi: 10.1038/s41467-024-53460-6) dividing forests into smaller areas via roads can directly result in an increased extreme wildfires. We need to protect our beautiful American forests from being marred by more potential roads. This would create a much more dangerous situation for surrounding communities, in many ways. The Roadless Rule protects old-growth forest and significant carbon storage, which we need to continue to keep in mind because increasing wildfires are driven by global climate change. According to the Wilderness Society, wildfires are 4x more likely to start in roaded areas than in roadless forests. According to the Sierra Club, roughly 90% of wildfires start within half a mile of a road. I strongly object to this measure to remove protections from our public lands.