Comment Analysis · Docket FS-2025-0001

FS-2025-0001-533387

Opposes rescissionA2 moderateSubstance 4/24Owed an answerPosted October 4, 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

A2 moderate: Hard to dismiss — it shows cause and effect.

Owed an answer on Alternative.

Standard dismissals it defeats

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.

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.
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

Forest Management Wildfire
- “wildfires are 4 times more likely to start within 50 meters of a road”
- “human activity is responsible for about 90% of wildfires”
- “Increasing road access will likely exacerbate the risk of wildfire”
- “Existing exceptions in the roadless rule allow for for non-commercial thinning and fuel reduction activity”
Water Quality Quantity
- “fails to address how the repeal of this rule will impact clean drinking water”
- “primary reasons National Forests were created was to protect watersheds”
Environmental Protection Biodiversity
- “biodiversity necessary for a healthy forest”
- “introduce particular ecological harms such as invasive species and fragmentation of habitat”
- “allowing human access to formerly protected areas will increase the risk of... ecological harm”
Governance Policy Process
- “approach the issue forest by forest”
- “allowing each forest and community to create an EIS”
- “Forest Service is unable to appropriately manage and maintain lands and roads”

The comment

While the proposal to repeal the roadless rule has the noble goal of improving forest health, the Draft Environmental Impact Statement (DEIS) provides little evidence that the repeal will achieve this goal. It is true that research shows that fuel reduction projects and other scientifically based management activities tend to improve forest health, the DEIS offers little proof that the repeal will encourage or enable such projects and activities. In fact, existing evidence supports that allowing human access to formerly protected areas will increase the risk of wildfire and ecological harm, particularly because this repeal is intended to increase extractive uses and development on public land. The DEIS also fails to address how the repeal of this rule will impact clean drinking water and also, the biodiversity necessary for a healthy forest. This is particularly concerning because one of the primary reasons National Forests were created was to protect watersheds. Available evidence shows that wildfires are 4 times more likely to start within 50 meters of a road and that human activity is responsible for about 90% of wildfires. Increasing road access will likely exacerbate the risk of wildfire and make catastrophic wildfires more likely. Existing exceptions in the roadless rule allow for for non-commercial thinning and fuel reduction activity in protected areas. Beyond the harm this repeal would likely cause, another reason I oppose this repeal is a practical one. Due severe budget reductions, the Forest Service is unable to appropriately manage and maintain lands and roads outside these roadless areas. Forests were already severely understaffed prior to 2025 and were decimated by the DRP, VERAs, and firing of probationary employees in 2025. It is unlikely that the Forest Service would be able effectively manage lands with increased access. Building and maintaining roads is a costly, long term endeavor that can also introduce particular ecological harms such as invasive species and fragmentation of habitat. These harms outweigh any benefits provided by increased access. I strongly oppose this blanket repeal of the roadless rule as it exists. However, as noted, it has a welcome goal of improving forest management and reducing wildfire risk. Rather than a blanket repeal, a far better solution would be to approach the issue forest by forest, allowing each forest and community to create an EIS that appropriately considers all factors and allows for increase road access only where it makes sense.