Comment Analysis · Docket FS-2025-0001

FS-2025-0001-408134

Opposes rescissionA0 noneSubstance 2/24Posted September 15, 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
- “increase the risk of wildfires”
- “fragmenting or dividing forests into smaller areas via roads could directly result in an increased likelihood of extreme wildfires”
- “13% of roadless land currently protected has experienced wildfires of high or moderate severity”
- “construction of roads would directly increase this risk”
Scientific Research Evidence
- “A recent study, "Road fragment edges enhance wildfire incidence and intensity, while suppressing global burned area" by Bowring, Li, Mouillot, Rosan, and Ciais”
- “concludes that fragmenting or dividing forests into smaller areas via roads could directly result in an increased likelihood of extreme wildfires”
- “as per the Trump administration's Federal Register filing”
Environmental Protection Biodiversity
- “keep the Roadless Rule in place”
- “Repealing the 2001 Roadless Area Conservation Rule would cause immense harm to our country”
- “our beautiful forests, which are a source of pride for many Americans, be marred by these potential roads”
- “remove protections from our public lands”

What it names

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

The comment

I strongly urge you to keep the Roadless Rule in place! Repealing the 2001 Roadless Area Conservation Rule would cause immense harm to our country. It would actually increase the risk of wildfires, which are already a significant and growing risk to all. A recent study, "Road fragment edges enhance wildfire incidence and intensity, while suppressing global burned area" by Bowring, Li, Mouillot, Rosan, and Ciais (doi: 10.1038/s41467-024-53460-6), concludes that fragmenting or dividing forests into smaller areas via roads could directly result in an increased likelihood of extreme wildfires. In addition, 13% of roadless land currently protected has experienced wildfires of high or moderate severity between 1984 and 2024, as per the Trump administration’s Federal Register filing. The construction of roads would directly increase this risk. Not only would our beautiful forests, which are a source of pride for many Americans, be marred by these potential roads but they would also become much more dangerous to surrounding communities. I strongly object to this measure to remove protections from our public lands, and strongly urge the Department to keep the Roadless Rule.