Comment Analysis · Docket FS-2025-0001

FS-2025-0001-441184

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 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

  • Environmental Protection Biodiversity
    • “undisturbed wildlife habitats”
    • “put roughly 400 species on an "extinction fast track"”
    • “Habitat fragmentation: Grizzly bears, Canada lynx, and native salmon depend on large, connected landscapes”
  • Water Quality Quantity
    • “care deeply about clean water”
    • “Roads are a major cause of water pollution in these watersheds”
    • “increases sediment and runoff into drinking-water sources”
  • Climate Carbon Storage
    • “Climate and carbon storage”
    • “store roughly 20% of all carbon held in the national forest system”
    • “Logging these stands releases stored carbon”
  • Forest Management Wildfire
    • “Wildfire rationale is unsupported”
    • “studies show wildfires were four times as likely in areas with roads”
    • “evidence does not support the claim that removing roadless protections meaningfully reduces wildfire risk”

What it names

National Forests
Uinta National Forest

The comment

My name is Blake. I hold an advanced education and work as a software engineering director. I'm also an avid hiker and lifelong camper who, until recently, lived right next to the Uinta National Forest. I care deeply about clean water and undisturbed wildlife habitats, and I urge USDA to withdraw this proposal and keep the Roadless Rule intact. Roadless areas are the last large, unfragmented ecosystems in the National Forest System. Once a road is built, the ecological function of that land changes permanently — soil compacts, water flow shifts, and the area becomes permanently open to logging, mining, and motorized traffic. National forests already contain over 370,000 miles of roads with a maintenance backlog in the billions. Roadless areas are the exception, not the rule, and that scarcity is why they matter. Wildfire rationale is unsupported. USDA claims the rule is a "barrier to wildfire risk reduction." But studies show wildfires were four times as likely in areas with roads than in roadless tracts, since roads increase human-caused ignitions. USDA should reconcile this rationale with its own data before finalizing anything. Endangered species and habitat loss: A recent study modeling this rescission found it would put roughly 400 species on an "extinction fast track," putting 7.4 million acres of critical habitat and nearly 1,800 miles of protected rivers at risk, threatening 88 species with designated critical habitat in roadless areas. The EIS should quantify these risks forest-by-forest. Habitat fragmentation: Grizzly bears, Canada lynx, and native salmon depend on large, connected landscapes, not isolated patches. Every mile of new road segments habitat, disrupts migration corridors, and opens new vectors for invasive species. Clean water: National forests are the headwaters of the country's major rivers and the largest source of municipal water, serving over 60 million people across 33 states. Roads are a major cause of water pollution in these watersheds; removing protections increases sediment and runoff into drinking-water sources. Climate and carbon storage: Roadless areas and old-growth forest on the Tongass alone store roughly 20% of all carbon held in the national forest system. Logging these stands releases stored carbon and removes a natural climate buffer. Logging impacts don't justify the tradeoff: The Roadless Rule reduced national timber harvests by less than 0.5%; a marginal economic gain for a permanent ecological loss. USDA should show, forest by forest, that timber value actually exceeds the recreation, water, and carbon value being forfeited. And if the value of the timber is down to exceed all other value, the first should remain protected and untouched. Mining waste: Removing protections opens roadless land to new mineral-access roads, tailings, acid drainage, and heavy-metal contamination. Contaminated watersheds are far more expensive to restore than to protect in the first place. Social and economic impacts: Outdoor recreation in these landscapes supports jobs and local economies that compound over generations if the land stays intact; extractive revenue is largely one-time. When the Roadless Rule was finalized in 2001, more than 1.6 million people commented, the vast majority in favor of protection — one of the most extensive public engagement efforts in federal land-management history. This rescission was originally given only 32 days for comment, later extended to October 6, with just a handful of public hearings nationwide. A decision affecting tens of millions of acres deserves a proportionate process. I urge the Forest Service to withdraw this proposal and retain the 2001 Roadless Rule in full. The evidence does not support the claim that removing roadless protections meaningfully reduces wildfire risk, while the costs to endangered species, clean water, climate stability, and public lands are well documented and severe. On a personal note, my fondest memories of my children growing up was our weekly camping trip into the Uinta National Forest every summer. Immersing ourselves in nature--the sound of bird song while the breeze rustled the branches, the smell of pine and freshly fallen rain, the cool crisp air first thing in the morning, looking up at a clear sky framed by towering trees while the kids explored the trails near the campsite--provided a release, a resetting that is so desperately needed in today's increasingly stressful world. There is so much more to life and legacy than money. Nature reminds us of that. And it must be protected.

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