Comment Analysis · Docket FS-2025-0001

FS-2025-0001-524280

Opposes rescissionA1 strongSubstance 14/24Owed an answerPosted September 30, 2026 On Regulations.gov

In short: The comment documents that the proposed rescission lacks commensurate justification in the record, specifically by citing corrected GIS data contradicting agency claims about WUI proximity, peer-reviewed science on road-related wildfire ignition, and specific ecological threats to Whitebark Pine in the Rattlesnake Inventoried Roadless Area, while requesting that the final rule preamble address these corrected figures directly rather than via cross-reference.

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

A1 strong: Must be answered — it names the law.

Owed an answer on Analytical gap, Evidence, Legal.

Standard dismissals it defeats

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.
Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
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.

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.
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.

Topics

Environmental Protection Biodiversity
- “Whitebark Pine (Pinus albicaulis, G3, T) faces documented threat”
- “Road networks serve as vectors for the secondary impacts”
- “facilitate introduction of invasive species”
- “concentrate human disturbance along corridors through Whitebark Pine habitat”
Forest Management Wildfire
- “peer-reviewed science shows the opposite”
- “84% of all U.S. wildfires are human-caused”
- “Roads are the primary vector for human ignitions”
- “building roads into roadless areas is likely to result in more fires, not fewer”
Recreation Tourism Public Use
- “I enjoy hiking up into the wilderness area every summer”
- “I would hate to see logging or any road building in this area”
- “I would loose the ability to experience wilderness so close to home”
- “traveling through genuinely roadless country”
Public Opinion Support
- “more than 99.8% of submitters opposed the rescission”
- “76% of likely voters support the Roadless Rule”
- “bipartisan backing from 71% of Republicans, 80% of Democrats, and 80% of independents”
- “More than 100 members of Congress have co-sponsored the Roadless Area Conservation Act”

What it names

National Forests: Lolo National Forest
Roadless areas: Rattlesnake
Law cited: 556 U.S. 502 579 U.S. 211

The comment

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

Dear Secretary Rollins: The experience of traveling through genuinely roadless country has shown me that the 2001 Rule codified something the public had long sought but lacked the regulatory mechanism to secure — and the Department's proposed rescission would dismantle that mechanism without commensurate justification in the record. I live on Rattlesnake creek in Missoulla. I enjoy hiking up into the wilderness area every summer. I would hate to see logging or any road building in this area that so many of us Missoulians use. I would loose the ability to experience wilderness so close to home. Regarding the Rattlesnake in the Lolo National Forest, Montana: In the Rattlesnake Inventoried Roadless Area, Lolo National Forest, Whitebark Pine (Pinus albicaulis, G3, T) faces documented threat from 5.3 - Logging & wood harvesting at Slight or 1-10% pop. decline severity across Small (1-10%) scope. Road networks serve as vectors for the secondary impacts classified under 5.3 - Logging & wood harvesting: they open previously inaccessible terrain to resource extraction, facilitate introduction of invasive species, and concentrate human disturbance along corridors through Whitebark Pine habitat. Although proponents of rolling back the Roadless Rule claim it is needed for wildfire management, the peer-reviewed science shows the opposite A separate national analysis (Balch et al., PNAS 2017) found that 84% of all U.S. wildfires are human-caused. Roads are the primary vector for human ignitions, so building roads into roadless areas is likely to result in more fires, not fewer. Forest Service Chief Tom Schultz testified to the Senate that 24.5 million acres of inventoried roadless areas are within one mile of the Wildland-Urban Interface (WUI)—calling it "our primary concern." A GIS analysis by The Wilderness Society using the Forest Service's own data found the actual figure is just 2.8 million acres—a nearly ninefold exaggeration. Less than 5% of inventoried roadless area acreage is in close proximity to the WUI, not 42% as Schultz claimed. Building more roads in national forests would be a drain on taxpayers. Even with the Roadless Rule in place, the Forest Service already has a 380,000-mile road system—twice as long as the U.S. highway system—crisscrossing national forests. The agency cannot afford to maintain it: the deferred-maintenance road backlog was estimated at $8.4 billion in the 2001 Final Environmental Impact Statement and is roughly $15.6 billion in today's dollars. The Roadless Rule is one of America's most popular conservation measures, and that support has not faded. Prior to its 2001 enactment, more than 600 public hearings were held nationwide and 1.6 million Americans weighed in to call for protection of these forestlands—more comments than any other federal rule had received at the time. When USDA announced its rescission proposal, the compressed 21-day public comment period in late 2025 drew approximately 600,000 additional comments. A detailed roadless.org analysis of the comment record found that more than 99.8% of submitters opposed the rescission. A February 2026 Pew Charitable Trusts national poll found that 76% of likely voters support the Roadless Rule compared to just 13% opposed, with bipartisan backing from 71% of Republicans, 80% of Democrats, and 80% of independents. More than 100 members of Congress have co-sponsored the Roadless Area Conservation Act of 2025 (S.2042 / H.R.3930) to codify the Rule so it could not be rolled back without an act of Congress. Finally, these figures serve the final rule as well as the environmental impact statement. The proposal reverses findings the Department made in 2001 about the effect of roadless protections on management, and this FACTS baseline is the factual finding on which that reversal rests. Where a new position rests on factual findings that contradict those underlying the prior policy, the explanation must be more detailed, not less. FCC v. Fox Television Stations, 556 U.S. 502, 515–16 (2009); Encino Motorcars, LLC v. Navarro, 579 U.S. 211, 221–22 (2016). I request that the final rule preamble address the corrected figures and the disaggregated series directly, and not by cross-reference to the FEIS response-to-comments appendix. Rescission serves the fewest. The Rule serves the most. Keep the Rule. Warm regards, Daniel Volkmann