Opposes rescissionA0 noneSubstance 3/24Posted 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.
“introduction and dispersal of non-native plant species”
“contributing to pollution, invasive species”
“maintain areas currently accessible to the public”
What it names
Works cited
10.1016/j.scitotenv.2023.16939210.1073/pnas.161739411410.1111/j.1523-1739.2008.01162.xBalch et al. 2017
The comment
My name is Emilee Simpson and I am an undergraduate biology student at Brigham Young University. I am writing to express my opposition to the rescission of the 2001 Roadless Area Conservation Rule. One of the main reasons why I am opposed to this rescission is that construction of access roads through national forest lands can fragment habitats and isolate wildlife populations. Many animals exhibit a strong aversion to roads because of traffic noise and artificial light (Xiong et al., 2025). Roads can also restrict wildlife movement between habitat patches, potentially reducing gene flow and increasing genetic isolation between populations (Corlatti et al., 2009). Over time, reduced connectivity can make populations more vulnerable to environmental change and other disturbances. Although increased roads may provide flexibility for forest management and wildfire response, human activity is also an important consideration. Balch et al. (2017) found that human-started fires accounted for 84% of recorded wildfires in the United States from 1992-2012. Increasing road access could provide more opportunities for human activity and potentially create additional ignition sources. Increased road access to address wildfire risk could overlook the important role that humans already play in wildfire occurrence. Road construction and subsequent vehicle traffic can also facilitate the introduction and dispersal of non-native plant species, creating another potential issue associated with expanding road networks (Son et al., 2024).
Another, more personal reason I am opposed to this rescission is because of the experiences I have had in National Forests with my family. Some of my favorite memories have been created by backpacking and hiking into extremely remote, pristine areas of our National Forests. These experiences have given me an appreciation for places where people can escape and experience nature with little human disturbance. I am concerned that increasing the number of roads will greatly increase access to some of my favorite spots and could change by increasing human use and disturbance. I am also concerned about the potential for increased access to contribute to pollution, invasive species, and other impacts. I believe that expanding access should be approached carefully, especially because of the existing challenges associated with maintaining areas currently accessible to the public. For these reasons, I am in favor of retaining the 2001 Roadless Area Conservation Rule rather than rescinding it. Thank you for taking the time to read my comment and I hope you consider my concerns.
References:
Balch, J. K., Bradley, B. A., Abatzoglou, J. T., Nagy, R. C., Fusco, E. J., & Mahood, A. L. (2017). Human-started wildfires expand the fire niche across the United States. Proceedings of the National Academy of Sciences, 114(11), 2946–2951. https://doi.org/10.1073/pnas.1617394114
Corlatti, L., Hacklander, K., Frey-Roos, F. (2009). Ability of wildlife overpasses to provide connectivity and prevent genetic isolation. Conservation Biology, 23(3), 548-56. DOI: 10.1111/j.1523-1739.2008.01162.x.
Son, D., Chu, Y., & Lee, H. (2024). Roads as conduits for alien plant introduction and dispersal: The amplifying role of road construction in Ambrosia trifida dispersal. Science of The Total Environment, 912, Article 169392. https://doi.org/10.1016/j.scitotenv.2023.169392
Xiong, G., Yang, F., Wang, T., He, R., and Li, L. (2025). Impact of road infrastructure on wildlife corridors in Hainan rainforests. Transportation Research Part D: Transportation and Environment, 139:104539.