Opposes rescissionA0 noneSubstance 5/24Posted 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.
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 eliminatedThe agency says it considered and eliminated the alternative the comment proposes, with a reason. Cannot be defeated from the comment text alone.
Already addressedThe 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 decisionThe agency says the point belongs to a later, site-specific decision. Cannot be defeated from the comment text alone.
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.
“77% of inventoried roadless areas have the potential to conserve threatened, endangered, or imperiled species”
“IRAs provide vital, undisturbed habitat for America's wildlife”
“The habitat of these species and more would be jeopardized by the recession of the Roadless Rule”
What it names
Roadless areas
Eagle Creek
Works cited
10.1073/pnas.161739411410.1111/csp2.28810.1186/s42408-026-00450-210.2489/jswc.66.3.78aBalch et al. 2017DellaSala et al. 2011
The comment
Repealing the Roadless Rule will not aid in wildfire mitigation. Rather, it will have devastating consequences on 44.5 million acres of American forests and the vital ecosystem services they provide. Therefore, as a concerned citizen who has worked in conservation and water resources and resident of Illinois, I oppose the recession of the Roadless Rule.
Roadless Areas Protect Drinking Water
DellaSalla, Karr, and Olson (2023) find that the development of roadless areas degrades water quality through sedimentation. Inventoried roadless areas (IRAs) are within the watersheds of many urban and rural municipal drinking water sources. The development of IRAs would lead to costly mass sedimentation, potentially costing municipalities millions of dollars. For example, Salem, Oregon had to spend $100 million on treatment facilities as a result of mass sedimentation due to logging in its watershed. Talty et al. (2020) have found that there are 10,929 HUC-12 watersheds wholly or partially contained within IRAs that have at least some of their area within a drinking water protection area. These provide drinking water to over 48 millions people. Keeping these IRAs roadless is essential to maintaining drinking water quality for millions of people.
Developing Roadless Areas is Detrimental to Fire Mitigation
Contrary to the justification provided for repealing the Roadless Rule Act, studies indicate that the development of roads in IRAs would be detrimental to fire mitigation efforts. In Fire Ecology, Aplet, Hartger, and Dietz (2026) find that IRAs had a significantly smaller wildfire-ignition density than lands within 50 m of roads, concluding that “…results suggest that building roads into roadless areas is likely to result in more fires.” Additionally, Balch et al. (2017) find that human-started wildfires make up at least 84% of wildfire and about half of total areas burned. They state that “ignitions caused by human activities are a substantial driver of overall fire risk to ecosystems and economies. Actions to raise awareness and increase management in regions prone to human-started wildfires should be a focus of United States policy to reduce fire risk and associated hazards.” Thus, repealing the Roadless Rule Act will not meaningfully assist in fire mitigation efforts and in fact may increase wildfire risks.
Roadless Areas Promote Biodiversity
According to Loucks et al. (2003), “77% of inventoried roadless areas have the potential to conserve threatened, endangered, or imperiled species.” IRAs provide vital, undisturbed habitat for America’s wildlife that faces increasing threats of habitat fragmentation and destruction. More than 80% of American mammal and reptile species and 90% of American bird, amphibian, and fish species can be found in IRAs, including 1400 species designated threatened or endangered by the Endangered Species Act. IRAs are an essential part of the conservation of American wildlife.
In my home state of Illinois, IRAs such as Eagle Creek provide irreplaceable habit for a variety of species. The intact canopy of IRAs provides temperature moderation that helps support whooping cranes (Grus americana). Intact forests that maintain cool microclimates and preserve hydrologic function also create habitat for Mead’s milkweed (Asclepias meadii). This undisturbed Southern Interior Mixed Hardwood Forest also supports species including French's shootingstar (Primula frenchii), gray myotis (Myotis grisescens), and tricolored bat (Perimyotis subflavus). The habitat of these species and more would be jeopardized by the recession of the Roadless Rule. The loss of these habitats will have negative effects on Illinois wildlife, recreation, tourism, and more.
The Roadless Rule is vital towards protecting wildlife habitat and protecting drinking water and should not be repealed.
Citations:
Dominick A. DellaSala, James R. Karr & David M. Olson (2011) Roadless areas and clean water, Journal of Soil and Water Conservation, 66:3, 78A-84A, http://doi.org/10.2489/jswc.66.3.78A
Aplet, G.H., Hartger, P. & Dietz, M.S. Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads.fire ecol 22, 8 (2026). https://doi.org/10.1186/s42408-026-00450-2
J.K. Balch, B.A. Bradley, J.T. Abatzoglou, R.C. Nagy, E.J. Fusco, & A.L. Mahood, Human-started wildfires expand the fire niche across the United States, Proc. Natl. Acad. Sci. U.S.A. 114 (11) 2946-2951,https://doi.org/10.1073/pnas.1617394114 (2017).
Loucks, C., N. Brown, A. Loucks, and K. Cesareo. 2003. USDA Forest Service roadless areas: potential biodiversity conservation reserves. Conservation Ecology 7(2): 5. [online] URL: http://www.consecol.org/vol7/iss2/art5/
Talty MJ, Mott Lacroix K, Aplet GH, Belote RT. Conservation value of national forest roadless areas. Conservation Science and Practice. 2020; 2:e288. https://doi.org/10.1111/csp2.288