Opposes rescissionA0 noneSubstance 3/24Posted September 16, 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 eliminatedThe agency says it considered and eliminated the alternative the comment proposes, with a reason. Cannot be defeated from the comment text alone.
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Misreads the proposalThe agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
Not requiredThe agency says the analysis the comment asks for is not required. Cannot be defeated from the comment text alone.
Preference notedThe 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 shownThe agency says the comment asserts a harm without showing how the action causes it. Defeated when the comment shows the mechanism.
Outside the scopeThe agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.
Certified not substantiveThe agency certifies the comment raises nothing substantive. Defeated when the comment alleges illegality, which is substantive by the definition the certification runs on.
I strongly oppose revisions to the 2001 Roadless Area Conservation Rule. We have very few natural areas remaining in our shared public spaces. The roadless rule is the best tool to ensure that these natural areas are preserved for future generations. By allowing the construction of roads for logging operations, increased motorized recreation, or for any other reason, these already very limited conservation areas will unquestionably be reduced and harmed.
Natural spaces are a gift to humanity and to our nation; they were here long before we took stewardship of the land, and we have a profound moral obligation to ensure that we preserve them. Permitting logging or increased motorized access is incredibly short-sighted - it puts the interests of a few current stakeholders above the interest of the billions in future generations who will inherit these lands.
We already have 149 million acres of national forest that are not subject to the roadless rule. The 44 million acres of protected forest is a tiny percentage of the land in our nation. The moment we introduce roads to these vanishingly few natural ecosystems, we will disrupt enormously complex ecological systems, further endangering already threatened species. We will also rob future Americans of the opportunity to witness undisturbed natural environments.
These spaces are irreplaceable. We cannot undo the impact of disruption.
I reject arguments that the introduction of roads to these spaces will allow local agencies to better manage healthy forest. I also strongly reject the notion that giving autonomy to local agencies is in the best interests of the nation. I live very near the Black Hills National forest in South Dakota and regularly spend time recreating in those spaces. I also value the contribution of the regional logging industry to our local communities and economy. However, the economic pressures and incentives that drive the logging industry are not always aligned with the best interests of future generations. Without the protection of the roadless rule, we will lose our irreplaceable natural spaces. It will only take a small mis-step from a regional authority, a few bad actors in the logging industry with good connections and deep pockets.
As James Madison once wrote, if men were angels, no government would be necessary. And the same principle is true here. This is too important to leave to chance. Preserve this rule for those who come after us.