Comment Analysis · Docket FS-2025-0001

FS-2025-0001-417736

Opposes rescissionA3 weakSubstance 12/24Owed an answerPosted September 16, 2026 On Regulations.gov

In short: The comment establishes that the agency's proposed rescission of the 2001 Roadless Area Conservation Rule contradicts its own 2020 study and other cited data indicating that fire risks are equal inside and outside roadless areas and that human-caused ignitions are more frequent near roads, thereby documenting a specific analytical deficiency in the agency's 'Wildfire Risk' assessment.

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 Analytical gap, Evidence.

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
- “vehemently and unequivocally opposed to the rescission”
- “contradicts its own analysis and studies on the subject”
- “fire risks are approximately equal inside and outside of roadless areas”
- “fires are four times more likely to start within 50 meters of roads”
Recreation Tourism Public Use
- “surrounded by the most pristine wilderness in the lower 48”
- “Recreating in these areas... has been my pursuit of happiness”
- “It is where I have gone during times where I had nothing left to live for”
- “a few good quiet places left upon this earth to rest in”
Scientific Research Evidence
- “2020 study titled “Long-Term Forest Health Implication of Roadlessness””
- “report “Three-decade record of contiguous-U.S. national forest wildfires””
- “blatantly ignoring widely accepted and respected data”
- “request to know why... the agency is departing from those prior findings”

What it names

National Forests: Bitterroot National Forest Lolo National Forest Lolo National Forest

The comment

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

I am Maxwell Johnson, a Wildland Firefighter in Idaho who is vehemently and unequivocally opposed to the rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001. Immediately after graduating high school in Florida, I moved across the country to Missoula, Montana, a place which I had never visited without a family or friend within a 1,000 miles. I came to Missoula for exactly one reason, because it is surrounded by the most pristine wilderness in the lower 48. I am not referring to the asphalt-scarred, overcrowded and endlessly commercialized Yellowstone and Glacier National Parks but rather the untouched roadless areas of Selway-Bitterroot, Bob Marshall and Lolo National Forest. Recreating in these areas and countless others Montana has been my pursuit of happiness. It’s my church and where I practice my religion. It is where I have gone during times where I had nothing left to live for to have my lust for life restored. The repeal of the 2001 roadless act is an existential threat to all of this. It will simultaneously remove restrictions from 405,883 acres in the Selway-Bitterroot NF, 758,433 acres in Lolo NF and over 1.5 million acres in the Bob Marshall Wilderness. Many have written expertly about the catastrophic impact the repeal of this rule will have on the environment and recreation and of these areas and the thought of this devastation has caused me to weep. But today I would like to move past emotional appeals and address the agency's claims about my own field, Wildland firefighting, which I possess the expertise to empirically disprove. The agency's claim that roadless areas have higher fire risk and road access is required to mitigate these fire risks contradicts its own analysis and studies on the subject. I am specifically referring to the text of the proposed rule under “Summary of potential impacts,” subsection “Wildfire Risk” which states, “While greater public access can increase human-caused ignition potential in some locations, the 2001 Roadless Rule's prohibitions have limited mechanical thinning options and some fire control tactics in inventoried roadless areas. Substantial acreage within potentially affected inventoried roadless areas has a relatively high likelihood of burning under high intensity conditions that are difficult to manage or could pose a risk to communities…” The agency provides no further justification for these claims while its own 2020 study titled “Long-Term Forest Health Implication of Roadlessness" conclude, “fire risks are approximately equal inside and outside of roadless areas… with the benefit of twenty years of monitoring, the best available records do not support speculation that roads are needed in IRAs to maintain forest health.” This study includes particularly accurate and complete data of Montana forest and roadless areas in the Selway-Bitterroot, Bob Marshall and Lolo National Forest. I want the agency to explain, specifically and in writing, why it is departing from those prior findings, and to reconcile the rescission with this study. Countless other reports and studies come to the same conclusion with some such as the report “Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads” finding that fires are four times more likely to start within 50 meters of roads than in roadless areas. This was a trend seen across all regions, not just “some areas,” as the proposed rule describes. The study notes the higher rate of ignition is due to human rather than lightning caused fire which according to a study by the agency itself acknowledges these make up 84% of wildfire ignitions, with lightning accounting for the remaining 16%. A 2020 study of California Wildfires found that those human caused fires spread quicker, burn more intensely and kill more trees than lightning caused fires. I again request to know why, specifically in writing, the agency is blatantly ignoring widely accepted and respected data on the subject in its rescission when it claims in direct opposition to it “that inventoried roadless areas have a relatively high likelihood of burning under high intensity conditions.” I have not just read these studies, I have lived and worked them, through smoke choked lungs and calloused hands, through a week straight of 16 hour days, fighting fire. As a Wildland Firefighter, I don’t ask to be paid more than $16 an hour and I don’t ask to be taken care of in 20 years when my lungs and legs will be shot and broken from this work. I do ask that the U.S. government stops its recession of the 2001 rule, so that I may be allowed to do my job free of meddling and so that when the job is done I may have a few good quiet places left upon this earth to rest in. Thank you for your time. Sincerely, Maxwell Johnson Coolin, Idaho