Comment Analysis · Docket FS-2025-0001

FS-2025-0001-378564

Opposes rescissionA0 noneSubstance 5/24Posted September 14, 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
- “Roads in wild areas only increase the spread of these fires”
- “The idea that road building will reduce the likelihood and manageability of these fires is one that has been disproven”
- “more roads actually exacerbate the frequency and intensity of the fires”
- “To rescind the Roadless Rule would be a careless decision, and would only increase the damage that this action aims to prevent”
Scientific Research Evidence
- “policy doing what the science would ask of it”
- “The research that I've included here, alongside countless other studies has shown that more roads actually exacerbate the frequency and intensity of the fires”
- “Fire Ecology (Springer Nature), 2026”
- “wildfire-ignition density was lowest in designated wilderness areas”
Environmental Protection Biodiversity
- “preservation of our countries natural and rural areas as they exist today”
- “I mourn the loss of the beautiful environments that fill my childhood memories”
- “threatened the people and places that I value”

What it names

National Forests: Wasatch-Cache National Forest
Works cited: 10.1186/s42408-026-00450-2

The comment

Dear Secretary Rollins: As a young climate-aware citizen beginning my duty with civic engagement, I have found that my civic responsibility includes paying attention to land policy. There is no longer a separation between these policies and the preservation of our countries natural and rural areas as they exist today. The 2001 Roadless Rule is one of the cleaner cases of policy doing what the science would ask of it. I was raised on the east coast, but some of the most precious memories from my youth were family trips to visit my aunt who lived near Salt Lake City. Seeing the devastating fires throughout Utah, and specifically in the High Unitas and the Wasatch-Cache National Forest, saddens and terrifies me. I mourn the loss of the beautiful environments that fill my childhood memories, and I also fear for the safety of my family near the fires. Watching the fires unfold in Utah this summer was particularly stressful as they reached unseen intensities and threatened the people and places that I value. Roads in wild areas only increase the spread of these fires: “The highest wildfire-ignition density was in lands within 50 m of roads (7.99 fires/1000 ha), and the second highest wildfire-ignition density was in other national forest lands outside of the 50-m road buffers but not in wilderness or roadless areas (3.50 fires/1000 ha). Wildfire-ignition density was lowest in designated wilderness areas (1.75 fires/1000 hectares), followed closely by Inventoried Roadless Areas (1.97 fires/1000 ha). For human-caused, natural, and undetermined fires, wildfire-ignition density decreased as distance to road increased: in lands between 0 and 250 m from roads, 6 fires ignited per 1000 ha, whereas fewer than 2 fires ignited per 1000 ha at a distance class of over 2000 m from roads. — Fire Ecology (Springer Nature), 2026 (https://doi.org/10.1186/s42408-026-00450-2)” The idea that road building will reduce the likelihood and manageability of these fires is one that has been disproven time and time again. The research that I’ve included here, alongside countless other studies has shown that more roads actually exacerbate the frequency and intensity of the fires. To rescind the Roadless Rule would be a careless decision, and would only increase the damage that this action aims to prevent. With best wishes, Luisa Becker CommentID: RLC-20260913-8JRW3H