Comment Analysis · Docket FS-2025-0001

FS-2025-0001-365360

Opposes rescissionA0 noneSubstance 1/24Posted 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

  • 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”
    • “13% of roadless land currently protected experienced wildfires of high or moderate severity”
  • Water Quality Quantity
    • “removal of water-retaining vegetation”
    • “more water flowing back into rivers and out to sea rather than filling local aquifers”
    • “worsening drought risks”
  • Environmental Protection Biodiversity
    • “encroachment on the last few wild spaces”
    • “national forests further shrunk by economic encroachment”
    • “immense harm to our country”

What it names

Works cited
10.1038/s41467-024-53460-6

The comment

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 other danger presented is the removal of water-retaining vegetation, which will lead to more water flowing back into rivers and out to sea rather than filling local aquifers through natural soil saturation processes. One of the stated intents of this bill is to prevent wildfires: How does worsening drought risks and increasing chances of fire ignition accomplish this goal? I'm firmly against this encroachment on the last few wild spaces in this great country and know that I, along with many others, would be heartbroken to see our national forests further shrunk by economic encroachment.

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