Comment Analysis · Docket FS-2025-0001

FS-2025-0001-439336

Opposes rescissionA0 noneSubstance 7/24Posted September 17, 2026 On Regulations.gov

In short: The comment establishes that the commenter resides in Flagstaff, AZ, within the Coconino National Forest, and documents specific local and regional impacts of the proposed rescission on wildfire risk, wildlife habitat, water quality, and tribal rights in that location.

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

Wildlife Habitat
- “Roadless areas provide habitat for an estimated 60% of the nation's vulnerable wildlife”
- “put more than 300 protected species at risk: grizzly bears, Canada lynx, wolverines, spotted owls, and native fish”
- “Roads are a huge barrier to habitat, and disrupt migration corridors”
Water Quality Quantity
- “The protected areas supply drinking water to 20–25 million people”
- “Road construction and logging are major drivers of sediment and chemical runoff in headwater streams”
- “risks degrading water quality at the source for millions of downstream communities”
Tribal Sovereignty
- “Tribal nations have clearly and consistently opposed this rescission”
- “Roadless areas often overlap with lands of deep cultural, spiritual, and subsistence significance”
- “The National Congress of American Indians passed a resolution supporting retention of the rule”
Forest Management Wildfire
- “wildfires are ~four times more likely to ignite in areas with roads than in roadless forest”
- “Opening these areas to roads will likely increase the number of human-caused ignitions”
- “The current Roadless Rule already permits road construction for public health and safety needs”

What it names

National Forests: Coconino National Forest

The comment

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

To the U.S. Forest Service, My name is Megan Mitchell, I live in the Coconino National Forest in Flagstaff, AZ. It will come as no surprise that I firmly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. Repealing this rule would open an estimated 45 million acres to development and logging (this is similar in size to Washington state). I recreate on this land throughout the country. Frequently. From my own backyard around the Coco forest, to dispersed camping in UT, hiking in WA, backpacking in CO, and soaking in hot springs in NM. I find therapy and refuge in these spaces. Friends fill their freezers for their families with these areas. And my native brothers and sisters strongly oppose this proposal out of principle and respect for their culture and roots. Repealing the Roadless Rule would make my life considerably worse and I quite frankly am fired up and appalled at this continual threat. Below are reasons I disagree with repealing the act, and evidence-based information as support. Increased wildfire risk: This repeal is framed as a wildfire-safety measure, but the evidence does not support that claim. The vast majority of wildfires in the US are started by people. Studies have found that wildfires are ~four times more likely to ignite in areas with roads than in roadless forest. Over 90% of fires start within half a mile of a road. Research from the Pacific Biodiversity Institute and The Wilderness Society show that roads bring more vehicles, campfires, equipment sparks, and human traffic into forests that are the least fire-prone because they are remote. Opening these areas to roads will likely increase the number of human-caused ignitions. Harm to wildlife / ecosystems: Roadless areas provide habitat for an estimated 60% of the nation's vulnerable wildlife. The rescission would affect more than 7 million acres of critical habitat and put more than 300 protected species at risk: grizzly bears, Canada lynx, wolverines, spotted owls, and native fish. Roads are a huge barrier to habitat, and disrupt migration corridors / introduce sediment, invasive species, and disturbance into some of the only remaining wild landscapes left. For wide-ranging species like grizzly bears, that disconnect can be the difference between a viable and a declining population. I’ve experienced grizzlies and wolves in their natural habitats, how could I not be a fierce advocate for them? Threats to drinking water. The protected areas supply drinking water to 20–25 million people. Forest soils and root systems filter contaminants naturally, reducing the cost and chemical burden of treating that water before it reaches taps. Road construction and logging are major drivers of sediment and chemical runoff in headwater streams. Rolling back these protections risks degrading water quality at the source for millions of downstream communities.There is no excuse for risking water quality for this many Americans. The cost of new roads. This proposal is fiscally hard to justify. The Forest Service already manages more than 380,000 miles of road, and has a maintenance backlog between $7 billion and $10 billion on the roads it already has. The agency hardly receives enough financing to maintain its existing network. Building new roads into roadless areas only adds to the unfunded liability. This holds taxpayers hostage to infrastructure the Forest Service has demonstrated it cannot afford to maintain. Indigenous impact and opposition. Tribal nations have clearly and consistently opposed this rescission. Dozens of Tribes submitted formal comments and requested consultation during the initial comment period and USDA acknowledges that most Tribes consulted oppose the repeal. Roadless areas often overlap with lands of deep cultural, spiritual, and subsistence significance. These are hunting and fishing grounds, sacred sites, and traditional gathering areas stewarded by Tribes for generations. The National Congress of American Indians passed a resolution supporting retention of the rule. Does that opposition not deserve to be weighed heavily? A better path forward? If the genuine goal is wildfire resilience and forest health, there are more targeted, less destructive tools available. The current Roadless Rule already permits road construction for public health and safety needs, and it does not block fuels reduction, prescribed burns, or other active forest work. I encourage USDA to instead invest in: (1) prescribed burning and mechanical thinning focused on the wildland-urban interface, protecting communities at risk; (2) fully funding existing road maintenance before creating new liabilities; and (3) continued, good-faith consultation with Tribal nations on management of these lands. I urge you to take this comment and those of my peers with similar comments to heart. The health of our environment, wildlife, and resources is counting on you to make the right choice. Sincerely, Megan Mitchell