Comment Analysis · Docket FS-2025-0001

FS-2025-0001-361972

Opposes rescissionA0 noneSubstance 3/24Posted 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 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
- “habitat fragmentation”
- “significant negative effects on biodiversity”
- “loss of biodiversity”
- “biodiversity has economic value”
Forest Management Wildfire
- “fragmenting or dividing forests into smaller areas via roads could actually directly result in an increased likelihood of extreme wildfires”
- “construction of roads would further exacerbate this risk”
- “become much more dangerous to surrounding communities”
Recreation Tourism Public Use
- “I recreate on public lands multiple times per week”
- “protection and appreciation of public lands”
- “beautiful forests, which are a source of pride”

What it names

Works cited: 10.1038/s41467-024-53460-610.1146/annurev-resource-100518-09394610.1146/annurev.ecolsys.34.011802.132419

The comment

As an American citizen, repealing the Roadless Rule is a matter of great importance to me and would directly impact my life and the place I call home. I am a fifth generation resident of Montana, and the protection and appreciation of public lands is one of the greatest things those before me have passed on. I recreate on public lands multiple times per week, and I value them as natural resources but more importantly as the places that house our natural relatives. 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. Furthermore, the construction of roads in previously undeveloped habitat would result in habitat fragmentation, which is known to have significant negative effects on biodiversity, particularly resulting in biodiversity loss (see https://doi.org/10.1146/annurev.ecolsys.34.011802.132419). The biodiversity of this country is incredible, but has already been threatened many times and has required significant conservation work to maintain. Further habitat fragmentation due to the construction of roads and the resulting loss of biodiversity would have tremendous consequences, including on the economy. One argument for repealing the Roadless Rule is that the resulting logging and mining would benefit the economy, however, that is not the only economic factor to be considered. Studies have shown that the biodiversity has economic value and that the loss of biodiversity has negative impacts on the economy (see https://doi.org/10.1146/annurev-resource-100518-093946). There are many reasons to object to the repealing of the Roadless Rule. I strongly object to this measure to remove protections from our public lands and urge the Department to reconsider.