Opposes rescissionA0 noneSubstance 6/24Posted September 17, 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.
Already addressedThe 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 decisionThe agency says the point belongs to a later, site-specific decision. Cannot be defeated from the comment text alone.
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.
Date: September 17, 2026
To: U.S. Department of Agriculture, Forest Service
Subject: Public Comment Opposing the Rescission of the 2001 Roadless Area Conservation Rule
From: Kathryn Zdan
Location: Sharon, Connecticut
I. Personal Connection and Standing
I am writing to express my strong opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule and to urge the U.S. Forest Service to select Alternative 1 (No Action), keeping the 2001 Roadless Rule fully intact.
My personal connection to public lands spans from coast to coast. Growing up in California, annual family trips to the Modoc National Forest taught me to respect nature, navigate the wilderness, and build lifelong resilience and independence. Visits to Yosemite and Sequoia National Parks helped shape who I am today. Now living in Connecticut, I regularly hike sections of the Appalachian Trail, where access to protected, intact forests is vital to my mental and physical health. As an active volunteer with a local land trust—where I build and maintain trails using sustainable practices and manage invasive species—I understand firsthand the work required to steward healthy ecosystems.
II. Significant Substantive Concerns with the Draft EIS and Proposed Rule
1. Exacerbation of Wildfire Risk and Public Safety Impacts
Having lived in California as wildfires transitioned from occasional tragedies to predictable annual crises, I have witnessed friends lose homes and experienced weeks of dangerous, unbreathable air quality. The Draft EIS fails to adequately address how opening roadless areas will compound these hazards. Research indicates that human-caused ignitions are seven times higher on lands with roads than in roadless areas. Opening protected spaces invites increased ignition risks, threatening surrounding communities, wildland firefighters, livestock, and vulnerable populations who cannot shelter from hazardous smoke.
2. Fiscal Responsibility and Maintenance Backlog
The Forest Service currently faces a $6.9 billion road and bridge maintenance backlog. Proposing to spend taxpayer resources on new road construction while failing to maintain existing infrastructure raises severe concerns regarding fiscal responsibility and operational management. The agency must prioritize maintaining its current road network over creating new, costly infrastructure liabilities.
3. Protection of Watersheds, Ecosystem Services, and Tribal Sovereignty
Intact roadless areas provide irreplaceable ecosystem services—including clean drinking water for 24 million people, carbon sequestration, and critical wildlife habitat. Furthermore, I strongly oppose any action that undermines Tribal sovereignty or threatens sacred sites, treaty resources, and cultural places. Since lands have been removed from Native stewardship, hallmark measures of forest and habitat health have noticeably declined. Respecting Indigenous sovereignty and upholding Tribal input is essential for long-term ecological stability and public well-being.
III. Requested Action
The draft EIS fails to justify the long-term ecological, financial, and public safety costs of rescinding these protections. I formally request that the Forest Service abandon the proposed rescission entirely and adopt Alternative 1 (No Action) to ensure all inventoried roadless areas remain protected under the 2001 Roadless Rule.
Respectfully submitted,
Kathryn Zdan
Sharon, Connecticut