Comment Analysis · Docket FS-2025-0001

FS-2025-0001-451686

Opposes rescissionA0 noneSubstance 4/24Posted September 21, 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

Scientific Research Evidence
- “The scientific literature does not support the premise”
- “Aplet, Hartger, and Dietz (2026) found that wildfire ignition density was lowest in Inventoried Roadless Areas”
- “Healey (2020)... found no evidence that roadlessness prevented fire-management activities”
- “base its decision on the best available scientific evidence”
Environmental Protection Biodiversity
- “non-native plants were approximately twice as common within 152 meters of roads”
- “Inventoried Roadless Areas contain some of the nation's highest-integrity forests”
- “provide significant benefits including... biodiversity”
- “once roads and associated development fragment these landscapes, their ecological characteristics cannot readily be restored”
Forest Management Wildfire
- “opening Inventoried Roadless Areas to additional roads... will... reduce wildfire risk”
- “roads are associated with substantially greater wildfire ignition rates”
- “allowing additional roads into these areas... could increase wildfire risk”
- “using carefully targeted management tools where ecological or public-safety conditions warrant them”
Economic Impact Fiscal
- “Road construction also creates long-term financial obligations”
- “Forest Service already faces a substantial deferred-maintenance backlog”
- “careful consideration of the full life-cycle costs to taxpayers”

What it names

Works cited: Healey 2020U 2001

The comment

I respectfully urge the U.S. Department of Agriculture and Forest Service to withdraw the proposal to rescind the 2001 Roadless Area Conservation Rule. The scientific literature does not support the premise that opening Inventoried Roadless Areas to additional roads and timber development will improve forest health or reduce wildfire risk. In a nationwide analysis of Forest Service lands covering 1992–2024, Aplet, Hartger, and Dietz (2026) found that wildfire ignition density was lowest in Inventoried Roadless Areas (1.97 fires/1,000 hectares) and highest within 50 meters of roads (7.99 fires/1,000 hectares). Their findings indicate that roads are associated with substantially greater wildfire ignition rates, particularly human-caused ignitions. Similarly, Healey (2020), using nearly two decades of Forest Service monitoring data, found no evidence that roadlessness prevented fire-management activities or caused poorer forest health. He also found that non-native plants were approximately twice as common within 152 meters of roads, demonstrating an important ecological cost of road development. Recent research further demonstrates that Inventoried Roadless Areas contain some of the nation's highest-integrity forests and provide significant benefits including clean water, biodiversity, carbon storage, wildlife habitat, climate regulation, and cultural values (Mildrexler et al., Berner, Law & Booth, 2026). The authors conclude that allowing additional roads into these areas would degrade ecosystem functions and could increase wildfire risk. Road construction also creates long-term financial obligations. The Forest Service already faces a substantial deferred-maintenance backlog on its existing road network. Expanding that network before adequately maintaining existing infrastructure warrants careful consideration of the full life-cycle costs to taxpayers. The Roadless Rule does not prohibit all active forest management. Existing provisions allow specified activities, including certain fire, watershed, insect and disease, and public-safety actions. The scientific evidence therefore supports maintaining the protections while using carefully targeted management tools where ecological or public-safety conditions warrant them. I ask the Forest Service to base its decision on the best available scientific evidence and retain the 2001 Roadless Area Conservation Rule. Remaining roadless forests represent an increasingly scarce national resource, and once roads and associated development fragment these landscapes, their ecological characteristics cannot readily be restored. Thank you for considering my comments. Selected professional literature Aplet, G.H., Hartger, P., & Dietz, M.S. (2026). Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. Fire Ecology, 22, 8. Healey, S.P. (2020). Long-term forest health implications of roadlessness. Environmental Research Letters, 15, 104023. Mildrexler, D.J., Berner, L.T., Law, B.E., & Booth, M.S. (2026). Roadless rule rescission threatens highest integrity forest ecosystems in the United States. Biological Conservation, 111950. Gucinski, H., Furniss, M.J., Ziemer, R.R., & Brookes, M.H. (2001). Forest Roads: A Synthesis of Scientific Information. USDA Forest Service, General Technical Report PNW-GTR-509. Wisdom, M.J., et al. (2018). Research on roads, habitat fragmentation, and wildlife responses in national forest landscapes. DellaSala, D.A., & Frost, E. (2001). Research concerning fire ecology and the role of natural fire regimes in roadless forests. Law, B.E., et al. (2021). Research identifying high-priority western U.S. forests for climate mitigation and biodiversity conservation. Watson, J.E.M., et al. (2018). Research on the global importance of intact forest landscapes for biodiversity and ecosystem services.