Comment Analysis · Docket FS-2025-0001

FS-2025-0001-457912

Opposes rescissionA0 noneSubstance 6/24Posted 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

  • Environmental Protection Biodiversity
    • “preserving biodiversity and habitat”
    • “critical habitat for over 500 imperiled species”
    • “protect our national forests, endangered species”
  • Water Quality Quantity
    • “protects millions of acres that serve as the headwaters”
    • “risk introducing significant water pollution”
    • “clean water”
  • Forest Management Wildfire
    • “rescinding the roadless rule would actually increase wildfire risk”
    • “wildfires are four times more likely in areas with roads”
    • “wildfire-ignition density was lowest in designated wilderness areas”
  • Recreation Tourism Public Use
    • “frequently hike, camp, picnic and recreate”
    • “raised my children in these forests”
    • “pristine wilderness areas”

What it names

National Forests
Klamath National ForestLassen National ForestShasta-Trinity National ForestSix Rivers National Forest
Works cited
10.1186/s42408-026-00450-2

The comment

I am a voter in Anderson, California. I frequently hike, camp, picnic and recreate in the Shasta-Trinity National Forest, the Lassen National Forest, the Six Rivers National Forest, and the Klamath National Forest. I raised my children in these forests, and now as young adults they also frequently recreate there. I am writing to express my strong opposition to the proposal to rescind the nation's landmark roadless rule. This action would open nearly 45 million acres of pristine national forests to road construction, logging, and other development. The consequences of this decision would be far-reaching and devastating for our environment, wildlife, and communities. * Biodiversity: The roadless rule has been instrumental in preserving biodiversity and habitat. These untouched forests provide critical habitat for over 500 imperiled species. * Water Quality: The roadless rule protects millions of acres that serve as the headwaters for major rivers that supply drinking water to more than 60 million people across 33 states. By allowing road construction, we risk introducing significant water pollution to these vital water sources. * Fire Protection: Contrary to the administration's claims, rescinding the roadless rule would actually increase wildfire risk. Scientific studies have shown that wildfires are four times more likely in areas with roads compared to roadless forest tracts. This fact directly contradicts the justification being used to push this harmful proposal forward. My Northern California home area is acutely aware of fire danger: we've lived through massive, devastating wildfires the last several years. Any action that increases fire danger is a direct attack on citizens' lives and property. Top findings from the fire study cited below (Aplet, Hartger, & Dietz): 1. From 1992 to 2024, in all 8 contiguous-US Forest Service regions combined, wildfire-ignition density was lowest in designated wilderness areas (1.75 fires/1,000 hectares), followed closely by Inventoried Roadless Areas (1.97 fires/1,000 ha). 2. The highest wildfire-ignition density was in lands within 50 meters of roads (7.99 fires/1,000 ha), and the second highest wildfire-ignition density was in other national forest lands outside of the 50-m road buffers but not in wilderness or roadless areas (3.50 fires/1,000 ha). 3. The results show that ignition density is much higher near roads than away from them. Across the National Forest System and in every region examined, the density of wildfire ignitions within 50 meters of a road is higher than in wilderness, Inventoried Roadless Areas, or other national forest lands, often by quite a bit. I implore you to stand against the rescission of the roadless rule. Protect our national forests, endangered species, clean water, and the interests of the millions of Americans who benefit from these pristine wilderness areas. The legacy of our public lands and the health of our environment depend on your action to preserve the roadless rule. Sources/references: U.S. Fish and Wildlife Service, “USFWS Threatened & Endangered Species Active Critical Habitat Report,” Environmental Conservation Online System (ECOS), updated August 7, 2025, accessed April 29, 2026, https://ecos.fws.gov/ecp/report/ table/critical-habitat.html. NOAA Fisheries, “National ESA Critical Habitat Mapper,” updated February 18, 2025, accessed December 8, 2025, https://www.fisheries.noaa.gov/resource/map/national-esa-critical-habitat-mapper U.S. Forest Service, “Water Facts,” https://www.fs.usda.gov/managing-land/national-forestsgrasslands/water-facts. Southern Environmental Law Center, “For Virginians, Roadless Areas Mean Clean Drinking Water,” December 18, 2025, https://www.selc.org/news/for-virginians-roadless-areas-mean-clean-drinking-water; Friends of Shenandoah Mountain, “Water Quality,” accessed March 31, 2026, https://www.friendsofshenandoahmountain.org/water-quality.html U.S. Department of Agriculture Forest Service, “Summary of Public Water Systems and Populations Receiving Surface Drinking Water Supply From National Forest System Land,” GTR WO-100 (September 2022), https://www.fs.usda.gov/ research/publications/gtr/gtr_wo100/GTR-WO-100-Sup1.pdf Aplet, G.H., Hartger, P. & Dietz, M.S. Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. fire ecol 22, 8 (2026). https://doi.org/10.1186/s42408-026-00450-2

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