Comment Analysis · Docket FS-2025-0001

FS-2025-0001-469880

Opposes rescissionA3 weakSubstance 8/24Owed an answerPosted September 22, 2026 On Regulations.gov

In short: The comment documents specific economic, ecological, and safety deficiencies in the proposed rescission of the Roadless Rule, citing agency DEIS data on recreation losses, scientific studies on wildlife and wildfire risks, and watershed impacts to argue for maintaining current protections.

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

A3 weak: Substantive, but easier to set aside.

Owed an answer on Evidence.

Standard dismissals it defeats

Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
Outside the scope The agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.

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.
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.
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

Recreation Tourism Public Use
- “backpacked and hiked in many of our nation's roadless national forests”
- “minimum of $6.1 million in annual losses to recreationists”
- “quiet, remote and self-reliant recreation”
- “Local guides, outfitters, and communities depend heavily”
Wildlife Habitat
- “fragmentation from road building threatens population viability”
- “critical habitat ranges for over 400 imperiled animal and plant species”
- “irreplaceable contiguous migration corridors for large mammals”
- “unroaded forests maintain significantly higher biodiversity”
Water Quality Quantity
- “protects the clean drinking water supply for 25 million Americans”
- “degrade pristine watersheds that feed major municipal systems”
- “critical salmon-bearing rivers of Oregon and Washington”
- “forcing municipal water utilities to pass expensive filtration and treatment costs”
Forest Management Wildfire
- “wildfires are four times more likely to start in areas served by roads”
- “90% of all wildfires on national forests starting within a half-mile of a road”
- “Introducing new roads... will drastically increase human-caused wildfire risks”
- “14 wilderness firefighters have lost their lives fighting forest fires”

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequestAlternativeLegal

Subject: Public Comment Opposing the Proposed Rescission of the Roadless Area Conservation Rule (Docket ID: FS-2025-0001 / RIN: 0596-AD66) Dear Chief Moore and U.S. Forest Service Officials, I am writing to express my strong opposition to the proposed rescission of the 2001 Roadless Rule. Having personally backpacked and hiked in many of our nation’s roadless national forests across the West—including the rugged peaks of Colorado, the lush backcountry of Washington and Oregon, and the diverse ecosystems of California—I know firsthand the irreplaceable ecological, economic, and spiritual value these intact wild lands provide. I urge the Forest Service to maintain current protections, a position strongly supported by recent agency data and independent scientific studies. My opposition is rooted in several critical areas of concern, backed by clear evidence: Severe Impacts on the Outdoor Recreation Economy & Outfitters: Roadless areas are the backbone of America’s outdoor recreation infrastructure. According to the Forest Service's own DEIS, repealing the Roadless Rule is projected to cause a minimum of $6.1 million in annual losses to recreationists and $9 million in lost recreation visitation expenditures. Local guides, outfitters, and communities depend heavily on what the DEIS acknowledges as opportunities for “quiet, remote and self-reliant recreation”. Forcing these small businesses to absorb millions in losses to support negligible logging increases—which the agency admits takes place on less than 1% of operable areas annually—is fiscally and socially irresponsible. Disruption of Critical Wildlife Migration & Habitats: National forests serve as vital sanctuaries, but fragmentation from road building threatens population viability. A comprehensive study published by the Center for Biological Diversity reveals that dismantling these protections overlaps with critical habitat ranges for over 400 imperiled animal and plant species. Across Colorado, Washington, Oregon, and California, these roadless lands provide irreplaceable contiguous migration corridors for large mammals like elk, mule deer, bighorn sheep, and wolves. Furthermore, mapping research published in Biological Conservation utilizes a "forest integrity score" demonstrating that unroaded forests maintain significantly higher biodiversity and ecosystem resilience. Fragmenting these continuous corridors with industrial roads will irrevocably bisect wildlife home ranges and accelerate localized extinctions. Increased Human-Caused Wildfire Risks: While the proposal cites wildfire preparedness as a justification for access, scientific data demonstrates the opposite outcome. Peer-reviewed analyses confirm that wildfires are four times more likely to start in areas served by roads than in roadless areas, with roughly 90% of all wildfires on national forests starting within a half-mile of a road. Introducing new roads into the vulnerable, fire-prone backcountry forests of California and the Pacific Northwest will drastically increase human activity and, consequently, human-caused wildfire risks to nearby communities. In this year alone, 14 wilderness firefighters have lost their lives fighting forest fires. Please don't increase this number by building more roads which will result in more fires. Loss of Watershed Integrity: I am deeply concerned about downstream impacts of this proposed decision. Research led by the University of Washington shows that the Roadless Rule currently protects the clean drinking water supply for 25 million Americans across 80,000 miles of rivers. Stripping protections will degrade pristine watersheds that feed major municipal systems—from the Colorado River headwaters to the critical salmon-bearing rivers of Oregon and Washington—forcing municipal water utilities to pass expensive filtration and treatment costs onto taxpayers. Rescinding the Roadless Rule swaps permanent, multi-billion-dollar ecosystem services for minimal, short-term commercial extraction. Specifically, the U.S. Small Business Administration estimates that the increase in the timber harvest that would result from the abandonment of the Roadless Rule would generate $4.6-10.6 M a year in increased timber industry revenue. This revenue increase falls far short of offsetting the decline in the recreation and tourism revenue that will accompany the change- $16M+) ---let alone compensate for the destruction of wildlife habitat, increased forest fires and reduced clean water for 25 million americans Having experienced the solitude and untamed beauty of these roadless landscapes across Colorado, Washington, Oregon, and California, I urge the Forest Service to heed its own impact analyses and the broader scientific community by upholding the 2001 Roadless Rule. Thank you for your time and for considering my comments. Sincerely, Kenneth C. Dunn, Boulder, CO 80302[