Opposes rescissionA0 noneSubstance 6/24Posted 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
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.
No cause and effect shownThe agency says the comment asserts a harm without showing how the action causes it. Defeated when the comment shows the mechanism.
Outside the scopeThe agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.
Certified not substantiveThe agency certifies the comment raises nothing substantive. Defeated when the comment alleges illegality, which is substantive by the definition the certification runs on.
The 2001 Roadless Area Conservation Rule is a crucial piece of legislation that, when initially proposed, had a final environmental impact statement that "...sought to meet the public's sentiment for protection roadless areas and the clean water, biological diversity and dispersed recreational opportunities, wildlife habitat, forest health and other public benefits provided by these areas." Based on the comments I've seen from the public over the many years, as well as in response to the U.S. Forest Service seeking to repeal this act now, the public still holds strong to these values being protected back in 2001 when the rule was enacted. Nothing has changed.
Arguments have been made that this rule has acted as a barrier to fighting forest fires, specifically Tom Schultz of the Forest Service stated, "For nearly 25 years, the Roadless Rule has frustrated land managers and served as a barrier to action – prohibiting road construction, which has limited wildfire suppression and active forest management," To my knowledge, Tom Schultz does not support his claim with any evidence. On the contrary, in a study conducted by the National Institutes of Health reported that 78 percent of human caused wildfires happen half a mile from roadways. (see citation 1) Creating more roadways will not fix the issues with fighting wildfires, it will exacerbate it. More roads means more areas for potential wildfires to start, its nonsensical to cut down the forest in favor of roadways to save them from wildfires, when the presence of the roadways themselves are part of the problem to begin with.
Another factor that is often brought up to support the repealing of this rule is timber production. By repealing this act it will open up more land to extract timber for construction and energy production. But we have safer and more effective forms of energy production in the form of green energy at our finger tips that could be used for energy production that does not risk conservation lands and endangered species. Wood has been on the decline as a major energy resource and in an assessment from the FAO of the UN. (see citation 2) Timber is not an essential enough resource to demand the destruction of these lands. Efforts to revitalize the United States timber industry is a wasted effort that seeks to maintain a form energy production that does not stand up to the wants, desires and needs of the American population. And the repealing of this rule is a consequence of this poor judgement from the current administration.
No statements or evidence provided in support of repealing the 2001 Roadless Area Conservation Rule has convinced myself or other members of the public that this is a necessary or needed effort. Please reconsider this proposition and keep our wild areas wild and road free.
Citations
1. Bowring SPK, Li W, Mouillot F, Rosan TM, Ciais P. Road fragment edges enhance wildfire incidence and intensity, while suppressing global burned area. Nat Commun. 2024 Oct 24;15(1):9176. doi: 10.1038/s41467-024-53460-6. PMID: 39448625; PMCID: PMC11502787.
2. FAO. 2022. Global forest sector outlook 2050: Assessing future demand and sources of timber for a sustainable economy – Background paper for The State of the World’s Forests 2022. FAO Forestry Working Paper, No. 31. Rome.