Opposes rescissionA0 noneSubstance 4/24Posted September 22, 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
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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.
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Outside the scopeThe agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.
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“conservation efforts should avoid building new roads in areas that have few or none”
“negative effects were concentrated in areas not highly altered by humans”
What it names
Works cited
10.1016/j.gecco.2019.e0055510.1046/j.1523-1739.2000.99084.x10.1111/avsc.7006210.5751/es-02815-140121Andrews et al. 2015Benítez-López et al. 2010
The comment
Scientific Reasons to Keep Roadless Areas Roadless
Comment on Docket FS-2025-0001, Special Areas; Roadless Area Conservation
Decades of research on the ecological effects of roads have been synthesized in reviews and meta-analyses that reach consistent conclusions. Five syntheses support retaining the 2001 Roadless Area Conservation Rule. The four that report study counts range from 21 to 1,098 studies.
Roads reduce wildlife populations well beyond the road itself. In an empirical review of 79 studies covering 131 species, Fahrig and Rytwinski (2009) found that documented negative effects of roads on animal abundance outnumbered positive effects by a factor of five (114 negative responses, 22 positive, 56 with no effect). Amphibians, reptiles, and large mammals tended to respond negatively. The authors concluded that the evidence for population-level effects is strong enough to merit routine consideration in all road construction projects. A meta-analysis of 49 studies on 234 mammal and bird species (Benítez-López et al. 2010) found that densities declined near infrastructure such as roads, with effects reaching up to about 1 km for birds and about 5 km for mammals. A road's ecological footprint is therefore far larger than its physical footprint.
Roads spread invasive species. A review of 1,098 studies (Lázaro-Lobo and Ervin 2019) found that over half examined exotic or weedy plants alone, and all but one of those reported that roadsides promoted their spread. A 2026 meta-analysis of 21 studies from 10 countries (Furtado et al.) found roadside plots had 46% more non-native species, reduced vegetation structure, and a shifted species composition compared with plots farther from roads. Lázaro-Lobo and Ervin also found that roadsides benefited native species most in landscapes already heavily altered by agriculture, urbanization, and forest management, while negative effects were concentrated in areas not highly altered by humans. That describes the condition of roadless areas.
Effects reach both land and water. In a foundational review of the scientific literature, Trombulak and Frissell (2000) concluded that roads are associated with negative effects on biotic integrity in both terrestrial and aquatic ecosystems. They identified seven general effects: construction mortality, vehicle-collision mortality, altered animal behavior, altered physical and chemical environments, the spread of exotic species, and increased human use. They emphasized that conservation efforts should avoid building new roads in areas that have few or none.
References
•Fahrig, L., and T. Rytwinski. 2009. Ecology and Society 14(1): 21. doi:10.5751/ES-02815-140121
•Benítez-López, A., R. Alkemade, and P. A. Verweij. 2010. Biological Conservation 143(6): 1307–1316. doi:10.1016/j.biocon.2010.02.009
•Lázaro-Lobo, A., and G. N. Ervin. 2019. Global Ecology and Conservation 17: e00555. doi:10.1016/j.gecco.2019.e00555
•Furtado et al. 2026. Applied Vegetation Science. doi:10.1111/avsc.70062
•Trombulak, S. C., and C. A. Frissell. 2000. Conservation Biology 14: 18–30. doi:10.1046/j.1523-1739.2000.99084.x