Comment Analysis · Docket FS-2025-0001

FS-2025-0001-556181

Opposes rescissionA3 weakSubstance 9/24Owed an answerPosted October 5, 2026 On Regulations.gov

In short: The comment places on the record specific scientific data and local observations from the Tonto National Forest and Boulder Roadless Area demonstrating that road construction increases wildfire ignition density and invasive species spread, thereby contradicting the agency's justification for rescinding the 2001 Roadless Rule.

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

Forest Management Wildfire
- “evidence strongly contradicts the government's claims that rescinding the Roadless area rule will reduce wildfire risk”
- “Any road-building would greatly increase the already very real wildfire danger”
- “wildfire-ignition density was lowest in designated wilderness areas”
- “wildfires are almost twice as likely to occur in roaded areas as in roadless areas”
Environmental Protection Biodiversity
- “effects on the native ecosystems would be grievous”
- “road networks... cause habitat fragmentation”
- “invasive plant richness and density generally decrease with the distance from roads”
- “Road construction would fragment wildlife habitat”
Recreation Tourism Public Use
- “frequent hiker in wilderness areas”
- “roadless condition is fundamental to preserving wilderness and recreation”
- “degrade the primitive character that draws hikers here”
- “introduce motorized noise to backcountry trails”
Water Quality Quantity
- “fishing streams flow through undisturbed watersheds”
- “paddling on Sycamore Creek and Canyon Lake occurs without road-related erosion or sedimentation”
- “increase erosion into fisheries”

What it names

National Forests: Tonto National Forest
Roadless areas: BoulderLime CreekSycamore Creek
Works cited: 10.1111/ddi.7000210.1186/s42408-026-00450-2

The comment

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

To Whom it May Concern, I am writing as a concerned citizen, professor at Arizona State University, and frequent hiker in wilderness areas, to strongly oppose the recision of the 2001 Roadless Rule. As an educator, I submit these comments because the record of policy reversals is itself a record students will one day read, and the Department owes that future readership something more than administrative convenience dressed as regulatory reform. The devastation caused by the 2020 Bush Fire in the Tonto NF, caused by a vehicle malfunction, and resulting in 193,455 acres burned, will, it's immediately obvious, take this area generations to recover. Hiking in nearby roadless areas such as the Sycamore Trail and the Denton Trail, to say nothing of the Arizona Trail in the Boulder Roadless Area make it abundantly clear how this irreplaceable wilderness would be at even greater risk from the effects of road building. Likewise the nearby Lime Creek Roadless Area would be jeopardized. My wife and I have hiked into this backcountry area twice in the last five years. Its remoteness is a blessing for the fauna and the flora to say nothing of the people who pass through it. Any road-building would greatly increase the already very real wildfire danger, especially with the drought conditions we've had recently. More to the point, the evidence strongly contradicts the government's claims that rescinding the Roadless area rule will reduce wildfire risk. More particularly: The highest wildfire-ignition density was in lands within 50 m of roads (7.99 fires/1000 ha), and the second highest wildfire-ignition density was in other national forest lands outside of the 50-m road buffers but not in wilderness or roadless areas (3.50 fires/1000 ha). Wildfire-ignition density was lowest in designated wilderness areas (1.75 fires/1000 hectares), followed closely by Inventoried Roadless Areas (1.97 fires/1000 ha). For human-caused, natural, and undetermined fires, wildfire-ignition density decreased as distance to road increased: in lands between 0 and 250 m from roads, 6 fires ignited per 1000 ha, whereas fewer than 2 fires ignited per 1000 ha at a distance class of over 2000 m from roads. — Aplet et al., 2026 (https://doi.org/10.1186/s42408-026-00450-2) Moreover, currently, forty percent of lands within inventoried roadless areas have a high or very-high wildfire hazard potential, ranging from 5 percent in the Eastern Region to 60 percent in California. About 23 percent (10.2 million acres) of inventoried roadless areas managed under the 2001 Roadless Rule are within the wildland-urban interface (WUI), areas where human development intermixes with the wildland, based on the definition of WUI set out in the Healthy Forests Restoration Act of 2003. — Department of Agriculture, Forest Service, 2025 (https://www.federalregister.gov/documents/2025/08/29/2025-16581/special-areas-roadless-area-conservation-national-forest-system-lands) Also, wildfires are almost twice as likely to occur in roaded areas as in roadless areas, because roadless areas are generally located further away from communities and are harder to access — U.S. Senate, 2025 (https://www.congress.gov/bill/119th-congress/senate-bill/2042/text) Aside from the increased wildfire danger the rescission would cause, the effects on the native ecosystems would be grievous. For instance, road networks are a common disturbance on the landscapes that cause habitat fragmentation and create edges with high resource availability that can act as important channels for the spread of invasive alien plants in various habitats, including nature reserves. Roads serve as dispersal corridors where invasive plant propagules are spread by humans, vehicles and animals using roadways as travel paths. Research indicates that invasive plant richness and density generally decrease with the distance from roads, whereas native species show variable distribution patterns near roads. Proximity to roads often correlates with higher invasion rates, reducing native diversity. — Dai et al., 2025 (https://doi.org/10.1111/ddi.70002) More particularly, in the Boulder Roadless Area, the roadless condition is fundamental to preserving wilderness and recreation. Maintained trails remain free from motorized competition; fishing streams flow through undisturbed watersheds; paddling on Sycamore Creek and Canyon Lake occurs without road-related erosion or sedimentation; etc. Road construction would fragment wildlife habitat, increase erosion into fisheries, introduce motorized noise to backcountry trails, and degrade the primitive character that draws hikers here. In conclusion, I plead with you for the good of us all and not just the few who stand to profit, not to proceed with the rescission of the Roadless area rule. Sincerely, Christopher D. Johnson CommentID: RLC-20261005-GYX9A0