Comment Analysis · Docket FS-2025-0001

FS-2025-0001-367638

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 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

Climate Carbon Storage
- “Carbon/heat sinks like our old-growth, national forests are shrinking”
- “mitigate extreme weather that causes heat illnesses”
- “record-breaking summer”
- “improving quality of life where we already reside”
Forest Management Wildfire
- “wildfires are 4x more likely to start in areas with roads”
- “fragmenting forests via roads could actually directly result in an increased likelihood of extreme wildfires”
- “death and destruction from increasingly widespread, dangerous wildfires”
- “90% of wildfires start within half a mile of a road”
Public Health Wellbeing
- “heat-intolerant, asthmatic disabled person”
- “negative impact on public health in general”
- “decrease my access to the outdoors specifically”
- “respiratory problems in many of my fellow disabled people”
Environmental Protection Biodiversity
- “protecting undeveloped, biodiverse areas”
- “expanding protection of these vital, natural areas”
- “enormous step back from what we need”
- “humans continue to expand their spread into the wild”

What it names

Works cited: 10.1038/s41467-024-53460-6

The comment

It's been a sweltering 100+ degree record-breaking summer here in Baltimore. Rescinding the Roadless Rule would be an enormous step back from what we need in this and all areas of the world. Carbon/heat sinks like our old-growth, national forests are shrinking and disappearing as humans continue to expand their spread into the wild, rather than improving quality of life where we already reside. According to the Wilderness Society, wildfires are 4x more likely to start in areas with roads than in roadless forests. From the Sierra Club: roughly 90% of wildfires start within half a mile of a road. A recent study (doi: 10.1038/s41467-024-53460-6) concludes that fragmenting forests via roads could actually directly result in an increased likelihood of extreme wildfires. We have already seen more than enough death and destruction from increasingly widespread, dangerous wildfires in this country's last few years. I am a heat-intolerant, asthmatic disabled person. Repealing the Roadless Rule would have a negative impact on public health in general and would decrease my access to the outdoors specifically. The priority needs to be protecting undeveloped, biodiverse areas to mitigate extreme weather that causes heat illnesses and respiratory problems in many of my fellow disabled people. Our national forests are one of the great gems of this land. We need to be expanding protection of these vital, natural areas, not decreasing them. Now more than ever.