Comment Analysis · Docket FS-2025-0001

FS-2025-0001-533175

Opposes rescissionA1 strongSubstance 14/24Owed an answerPosted October 4, 2026 On Regulations.gov

In short: The comment places peer-reviewed scientific evidence on the record demonstrating that rescinding the Roadless Rule would degrade water quality, release carbon stocks, and reduce wildlife habitat, while specifically requesting the agency to address the contradiction between the draft EIS's findings on increased fire and landslide impacts and the justification for new roads.

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, 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

Water Quality Quantity
- “IRAs provide clean water”
- “protect watersheds supplying drinking water”
- “degrade drinking water quality”
- “impacts on drinking water supplies”
Climate Carbon Storage
- “carbon storage”
- “hold 22% of the mature forest carbon stock”
- “release stored carbon and reduce future sequestration”
- “impacts on... carbon stocks”
Wildlife Habitat
- “wildlife habitat”
- “conserve threatened, endangered, or imperiled species”
- “Roads fragment habitat, introduce invasive species”
- “species of conservation concern”
Scientific Research Evidence
- “evidence-based science shows”
- “A 2026 study quantified the benefits”
- “peer-reviewed evidence above”
- “Research analysis associates intact forests with lower wildfire incidence”

What it names

Law cited: 36 CFR part 294
Works cited: 10.1016/j.biocon.2026.11195010.1016/j.gecco.2021.e0194310.1111/csp2.28810.1371/journal.pwat.000053810.5751/es-00528-070205

The comment

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

I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (36 CFR part 294, subpart B). The evidence-based science shows that Inventoried Roadless Areas (IRAs) provide clean water, carbon storage, wildlife habitat, and ecological integrity that would be put at risk if these protections were removed. The Forest Service's own analysis of the original Rule acknowledged that roads are the primary human-caused source of soil and water disturbance in forested environments (United States Department of Agriculture Forest Services 2000). Some IRAs protect watersheds supplying drinking water to hundreds of thousands of people (Talty et al. 2020). A 2026 study quantified the benefits IRAs provide for river protection, drinking water, and aquatic biodiversity, and warned that weakened protections could degrade drinking water quality (Olden et al. 2026). Removing road and harvest restrictions in these watersheds puts a service that cannot easily be replaced at risk. IRAs add disproportionately, relative to the area they cover, to the carbon captured by existing protected areas (Talty et al. 2020). IRAs hold 22% of the mature forest carbon stock and 27% of the old-growth carbon stock on national forest lands (Mildrexler et al. 2026). Mature and old forests also support biodiversity, water availability, and resilience to climate extremes (Mildrexler et al. 2026). Opening these lands to road building and commercial logging would release stored carbon and reduce future sequestration. Roadless areas on Forest Service lands are among the nation's most important biotic areas for conservation (Loucks et al. 2003). A later national analysis found that 77% of roadless areas had the potential to conserve threatened, endangered, or imperiled species, and that a handful of roadless areas hold a large share of suitable habitat for some species of concern (Dietz et al. 2021. Roads fragment habitat, introduce invasive species, and increase human disturbance, so losing roadless status would reduce the habitat these species rely on. A 2026 analysis found that IRAs contain higher-integrity forests than surrounding lands. Higher-integrity forests provide more clean water, biodiversity, cultural value, and climate regulation, and are associated with lower wildfire incidence (Mildrexler et al. 2026). The same analysis critiques the arguments offered to justify rescission. IRAs also buffer and connect existing protected lands, and about one-third of roadless forests border a national park or wilderness area (Talty et al. 2020). Rescission is sometimes justified to reduce wildfire risk. Research analysis associates intact forests with lower wildfire incidence (Mildrexler et al. 2026), and roads are a major source of human ignitions. I ask the Department to address this evidence in the final analysis and to explain specifically how new roads would reduce, rather than increase, fire risk, and costs. I also ask the Department to respond to the concern raised by commenters that the draft EIS itself shows increased fire, landslide, and cost impacts from rescission. I urge the Department to withdraw the proposal and retain the Roadless Rule. If the Department proceeds, it should fully analyze and respond to the peer-reviewed evidence above, including impacts on drinking water supplies, carbon stocks, and species of conservation concern, and consider alternatives that retain protections for the highest-integrity roadless areas. References Dietz MS, Barnett K, Travis BR, Aplet GH. 2021. The importance of U.S. national forest roadless areas for vulnerable wildlife species. Global Ecology and Conservation. 32:e01943. doi:10.1016/j.gecco.2021.e01943. [accessed 2026 Oct 3]. https://www.sciencedirect.com/science/article/pii/S2351989421004935. Loucks C, Brown N, Loucks A, Cesareo K. 2003. USDA Forest Service roadless areas: Potential biodiversity conservation reserves. Conservation Ecology. 7(2). doi:10.5751/es-00528-070205. Mildrexler DJ, Berner LT, Law BE, Booth MS. 2026. Roadless rule rescission threatens highest integrity forest ecosystems in the United States. Biological Conservation. 321:111950. doi:10.1016/j.biocon.2026.111950. [accessed 2026 Oct 3]. https://www.sciencedirect.com/science/article/pii/S0006320726002624. Olden JD, Postel SL, Dombeck MP, Kesting H, Freeman P, Comte L. 2026. Assessing the value of the U.S. roadless rule for people and nature. Ortega JCG, editor. PLOS Water. 5(7):e0000538. doi:10.1371/journal.pwat.0000538. Talty MJ, Mott Lacroix K, Aplet GH, Belote RT. 2020. Conservation value of national forest roadless areas. Conservation Science and Practice. 2(11). doi:10.1111/csp2.288. United States Department of Agriculture Forest Services. 2000. Forest Service Roadless Area Conservation . [accessed 2026 Oct 3]. https://www.fs.usda.gov/sites/default/files/roadless/roadless-feis-volume1.pdf.