Comment Analysis · Docket FS-2025-0001

FS-2025-0001-404813

Opposes rescissionA3 weakSubstance 10/24Owed an answerPosted September 15, 2026 On Regulations.gov

In short: The comment places on the record specific statistical evidence and a cited scientific study demonstrating that road density correlates with increased wildfire ignition risk and decreased elk habitat effectiveness, thereby documenting that the agency's proposed rescission of the Roadless Rule is contradicted by available data regarding wildfire and wildlife impacts.

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

A3 weak: Substantive, but easier to set aside.

Owed an answer on Evidence.

Standard dismissals it defeats

Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
Outside the scope The agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.

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.
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.
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

Wildlife Habitat
- “Roadless areas are essential wildlife habitat”
- “Elk habitat effectiveness declines roughly 25% once road density reaches one mile per square mile”
- “security cover, connectivity, and undisturbed watersheds that big game and native trout depend on”
Forest Management Wildfire
- “The agency's wildfire rationale is contradicted by the evidence”
- “wildfires are roughly four times more likely to start in roaded areas than roadless tracts”
- “Expanding roads into roadless areas would predictably increase ignition risk”
Recreation Tourism Public Use
- “genuine solitude”
- “I hunt and fish these landscapes myself”
- “Roadless National Forest lands are among the last places left for that kind of experience”
Water Quality Quantity
- “protect drinking water for 60 million Americans”
- “undisturbed watersheds that big game and native trout depend on”
- “once roaded, they do not return within any timeframe that matters to the... watersheds”

What it names

National Forests: Coconino National Forest San Juan National Forest

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapEvidenceLegal

Re: Comment in Opposition to the Proposed Rescission of the 2001 Roadless Area Conservation Rule Dear Director, I am writing in strong opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule ("Roadless Rule") and the accompanying Draft Environmental Impact Statement. I am a forest entomologist and Assistant Teaching Professor of Forestry at Northern Arizona University, where I have spent over fifteen years studying arthropod and plant communities across the Colorado Plateau, including field courses that bring students into roadless portions of the Coconino and Kaibab National Forests. I also conduct personal research and recreation in the roadless backcountry of the San Juan National Forest and the Dolores River canyon country of southwestern Colorado. I ask the Forest Service to withdraw this proposal and retain the Roadless Rule in its entirety. These lands are irreplaceable, and there are vanishingly few of them left. The National Forest System already contains over 370,000 miles of roads — roughly eight times the length of the entire U.S. Interstate Highway System. Despite this, only about 5% of the contiguous United States remains free of roads as inventoried roadless area or designated wilderness; the most remote point in the lower 48 states, in Yellowstone, is just 21.5 miles from a road. On the Coconino National Forest, roadless areas cover only about 10% of the forest; on the Kaibab, roughly 40%. These are the last remnants of an increasingly rare condition on the American landscape, and once roaded, they do not return within any timeframe that matters to the wildlife, watersheds, or people who depend on them. Roadless areas are essential wildlife habitat, and that matters directly to hunters and anglers. Elk habitat effectiveness declines roughly 25% once road density reaches one mile per square mile, and roughly 50% at two miles per square mile — thresholds already exceeded across much of the roaded National Forest System. Roadless areas provide the security cover, connectivity, and undisturbed watersheds that big game and native trout depend on. I hunt and fish these landscapes myself, and that experience is inseparable from their roadless character. These lands also hold the increasingly rare experience of genuine solitude — fifteen years ago I proposed to my wife on the banks of the Dolores River, miles from the nearest road, in a place defined by its silence. Roadless National Forest lands are among the last places left for that kind of experience. The agency's wildfire rationale is contradicted by the evidence, including my own field of research. A case-control study of ignitions in the eastern Cascades (Narayanaraj & Wimberly, 2012, Applied Geography) found human-caused ignitions strongly concentrated near roads and in high-road-density areas, while the largest, most destructive fires occurred disproportionately in remote, roadless terrain — driven by fuel continuity and weather, not road access. National-scale data reach the same conclusion: wildfires are roughly four times more likely to start in roaded areas than roadless tracts, and about 90% of ignitions occur within half a mile of a road. Expanding roads into roadless areas would predictably increase ignition risk in the hardest, most expensive places to defend, while doing little for the weather- and fuel-driven fires that account for most burned acreage. If community wildfire risk is the true concern, the evidence points to targeted fuel treatments near the wildland-urban interface — already permitted under the existing rule — not road-building across 44.7 million acres of protected forest. The proposal also ignores fiscal reality: the Forest Service already carries an $8.5 billion-plus deferred maintenance backlog on its existing road network, and building new roads into remote terrain would only deepen it. The Roadless Rule was built on one of the most extensively documented rulemaking records in Forest Service history and has functioned successfully for a quarter century to protect drinking water for 60 million Americans, wildlife habitat, old-growth forest, and recreation across 58.5 million acres in 39 states. As a forest scientist, educator, hunter, angler, and someone who has built some of the most meaningful moments of my life in roadless country, I urge the Forest Service to withdraw this proposal and retain the 2001 Roadless Area Conservation Rule in full. Sincerely, Dr. Derek Uhey Assistant Teaching Professor of Forestry, Northern Arizona University Coconino County, Arizona