Comment Analysis · Docket FS-2025-0001

FS-2025-0001-567149

Opposes rescissionA0 noneSubstance 6/24Posted October 5, 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

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.
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.

Topics

Environmental Protection Biodiversity
- “protect biological diversity”
- “damage ecosystems”
- “protect remote areas that provide wildlife habitat”
- “preserve American heritage and legacy”
Forest Management Wildfire
- “wildfires commonly ignite along roads”
- “building roads would open up areas to far more human-caused ignitions”
- “recipe for disaster”
- “natural history of fire”
Water Quality Quantity
- “clean water”
- “damage... water sources”
- “water and air filtration”
Economic Impact Fiscal
- “building roads in areas like the Tongass National Forest would be far too expensive”
- “not even benefit the timber industry”
- “costs of transporting logs to sawmills”

What it names

National Forests: Sequoia National Forest Tongass National Forest

Attachments

1 file. Counts as 1 — Counts as one: The attachments enclose no one else's submissions; the comment counts as one.

Own letter

The comment

The 2001 Roadless Rule should not be rescinded. The purpose of the Roadless Rule was to protect "roadless areas and the clean water, biological diversity, recreational opportunities, wildlife habitat, and other public benefits," (Forest Service 2001). The Forest Service claims that the rule should be repealed for "wildfire management" (Forest Service 2026). However, wildfires commonly ignite along roads, and while there is a need to treat forests in proximity to communities with thinning and prescribed burning to reduce wildfire risk, the Forest Service does not have the budget or resources to complete these activities even in the areas that have roads (Congressional Research Service 2023). It is clear that the true goal of the decision to repeal the Roadless Rule is not to "increase local management flexibility" or "allow for active management" (Forest Service 2026), but instead to abuse valuable natural landscapes for their timber and other resources. The current administration has explicitly stated its intentions to exploit the timber of our beautiful National Forests (Office of the Secretary 2025) and in the announcement of the Roadless Rule rescission, economic opportunity was offered as an important reason (Forest Service 2026). On its face, the rescission is presented to the public as necessary for active wildfire management, but rescinding the rule will remove a defense against clearcutting and mining that will damage ecosystems, water sources, wildlife habitat (Olden et al. 2026), and the fundamental beauty of our National Forests. Repealing the Roadless Rule would be a grave mistake and a huge loss to the American people. It is well known that roads increase the likelihood of ignitions (Aplet 2026), which may lead to more extreme wildfire events. According to Aplet et al. 2026, there is a much higher density of ignitions along roads than in Inventoried Roadless Areas. The Forest Service claims roads are needed to suppress fires (Forest Service 2026), but building roads would open up areas to far more human-caused ignitions, making the wildfire problem they are trying to solve far worse. And to be clear, the forests in the American West have a natural history of fire, which the Forest Service has altered through past management. Intelligent Indigenous burning -- intended to promote certain plants like berries (Lake and Christianson 2020) -- as well as fires ignited by lightning strikes, were important drivers of forest structure, and actually prevented extreme wildfire by consuming fuels on the ground before the forest could become dense (Agee 1993). Over the past hundred years, the Forest Service held a policy of fire suppression, allowing the forest to grow crowded with fuels. Climate change is also leading to hotter, drier, longer summers in the West, drying out the vegetation (Abatzoglou 2016). Adding ignitions to a forest system that has not experienced fire in a century, that has dense vegetation and debris, that has longer and drier summers every year, is simply a recipe for disaster. If the economy is the only value we care about, repealing the Roadless Rule would not even benefit the timber industry because building roads in areas like the Tongass National Forest would be far too expensive compared to the returns from the timber harvest. In 1995, building a road in the Tongass cost $160,000 per mile (Groenig 1995). Ignoring other factors, with inflation that would cost about $350,000 per mile today. This does not consider costs of transporting logs to sawmills, many of which have closed in the last 30 years (Crandall et al. 2025). Repealing the Roadless Rule is not good for the environment, nor is it good for the timber industry. One may ask, if there is no profit in clearcutting roadless areas, why not repeal the Roadless Rule? I would argue that just because logging is not profitable in wilderness does not mean it will never be profitable. The value of wood could increase, new technology could make road building less expensive, and repealing the Roadless Rule would remove a safeguard against short-sighted logging and mining. This is why we need the Roadless Rule, to protect remote areas that provide wildlife habitat, water and air filtration, carbon sequestration, and a host of other services that cannot be measured in dollars, but are essential to our economy and wellbeing. I have listed scientific reasons why the Roadless Rule should not be rescinded, but culturally, the rule should not be rescinded because it preserves American heritage and legacy. Once the wilderness is logged and mined out of existence, it will be gone, never to be enjoyed by future generations. Americans take great pride in the incredible landscapes that we have access to, from the immense trees in the Sequoia National Forest to the dramatic beauty of the Tongass. Rescinding the Roadless Rule, which protects numerous unique landscapes from extractive practices, will be at the cost of Americans’ legacy.