Comment Analysis · Docket FS-2025-0001

FS-2025-0001-405837

Opposes rescissionA3 weakSubstance 8/24Owed an answerPosted September 15, 2026 On Regulations.gov

In short: The comment places on the record specific statistical data regarding fire causation, road proximity to fire starts, and fuel treatment rates, alongside economic data on deferred road maintenance, to demonstrate that the proposed rescission of the 2001 Roadless Rule is unsupported by evidence and contradicts public support.

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

Forest Management Wildfire
- “studies, including those done by the USFS, show that road access increases chances of fire starts”
- “78% of fires started within 1/2 mi of a road”
- “fire hazard treatment to reduce fire risk is specifically allowed for in The Rule”
- “increasing the fire risk by removing the roadless protection is illogical”
Public Opinion Support
- “overwhelming support for The Rule by the public”
- “76% across all political identities, support roadless protection”
- “lacks public support”
- “key values associated with roadless areas by 95% of surveyed voters”
Recreation Tourism Public Use
- “sustaining local economies that rely on recreation, hunting, nature watching, and hiking”
- “I visit roadless areas to recreate numerous times every year”
- “Roadless areas serve as a foundation for my life and well-being”
Water Quality Quantity
- “irreplaceable value of roadless areas in regard to clean drinking water”
- “including municipalities”
- “protecting these values”

What it names

Works cited: 10.1073/pnas.1617394114

The comment

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

I oppose rescinding the 2001 Roadless Area Conservation Rule (The Rule). The justification and proposed alternative for rescinding The Rule are flawed and disregard the overwhelming support for The Rule by the public, who are the true landowners. The multi-year process that led to 2001 Roadless Rule was thorough and responsive to input, politics, the environment, and had overwhelming public support. While roadless public land continues to be a political football, the public support for roadless lands has not diminished. A current poll shows that a majority of U.S. citizens polled, 76% across all political identities, support roadless protection. The public remains quite clear about their position in favor of protecting their roadless public lands. The current justification to rescind The Rule is for fire protection via road building for fire preventive thinning and for easier access to fight fires when they ignite. However, studies, including those done by the USFS, show that road access increases chances of fire starts, and does not improve overall acreage affected by fires on roaded versus unroaded lands. Government data shows that 84% of wildfires in the U.S. between 1992 and 2012 were human-caused and more recently, 75% of fires were human-caused in a study of southern California. On USFS lands, 78% of fires started within ½ mi of a road. Roads are tied to increases in invasive plant species, such as cheat grass, that increase flammable fuels and outcompete ignition resistant native plants. Whether you apply science or common sense, roadless areas represent what is likely our best protection against ignitions on federal and adjacent private land through simple lack of human access. The data supports keeping them intact as our best safeguard against fire. Additionally, fire hazard treatment to reduce fire risk is specifically allowed for in The Rule. The USFS has already successfully thinned to reduce hazardous fuels on almost two million acres of roadless land. This represents 17% of roadless areas which is commensurate with the 19% thinning that has taken place on general forest lands. Broadcast burning accounts for about 50% of treatments in each designation of roadless and general forest land. Since fire protection/prevention treatments are already being practiced at nearly the same level in roadless as they are in general forest lands, increasing the fire risk by removing the roadless protection is illogical, environmentally and economically costly, and lacks public support. In regards to economics, as of 2024, the USFS had over 300,000 miles of road, with deferred road maintenance of over 5 million dollars and the same for other maintenance obligations such as buildings and bridges. Given the current reduction in force and budget, it’s a reasonable assumption that this obligation has not been reduced. The justification is just not there for the USFS to rescind The Rule, that has overwhelming public support, to build more roads that they can’t afford to maintain and that contradicts current evidence that more roads mean more fires. This is particularly true given that fire treatment efforts are already being successfully applied within roadless areas at basically the same rate as in general forest lands. The evidence for the irreplaceable value of roadless areas in regard to clean drinking water including municipalities, fish and wildlife habitat, and recreation are well documented and are the key values associated with roadless areas by 95% of surveyed voters. These same values are also essential to sustaining local economies that rely on recreation, hunting, nature watching, and hiking. Let’s focus on protecting these values by fortifying The Rule, not rescinding it. I visit roadless areas to recreate numerous times every year. I have worked and recreated in roadless areas in over a dozen States since childhood. Roadless areas serve as a foundation for my life and well-being and I consider it a basic right as a U.S. citizen that my government protect roadless areas as was agreed to by the 2001 Roadless Rule. References https://www.pew.org/en/research-and-analysis/articles/2026/02/18/an-update-on-the-roadless-rule) (https://www.pnas.org/doi/10.1073/pnas.1617394114, https://storymaps.arcgis.com/stories/4d9978ecdfb246e4a53b8a5681b631cb, https://research.fs.usda.gov/download/treesearch/61251.pdf, https://data.fs.usda.gov/geodata/edw/datasets.php?xmlKeyword=National+USFS+Fire+Occurrence+Point, https://www.fs.usda.gov/about-agency/features/fire-never-starts, (https://www.fs.usda.gov/sites/default/files/fs_media/fs_document/FY24-forest-system-stats.pdf) ( https://data.fs.usda.gov/geodata/edw/datasets.php?xmlKeyword=Hazardous+Fuel+Treatment, https://storymaps.arcgis.com/stories/4d9978ecdfb246e4a53b8a5681b631cb, https://www.sciencedirect.com/science/article/abs/pii/S0143622811001731)