Comment Analysis · Docket FS-2025-0001

FS-2025-0001-572036

Opposes rescissionA3 weakSubstance 5/24Owed an answerPosted October 6, 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

A3 weak: Substantive, but easier to set aside.

Owed an answer on Analytical gap.

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
- “maintaining biodiversity, ecological resilience”
- “degrading the value of the land for biodiversity”
- “opportunities for people to directly experience nature”
Forest Management Wildfire
- “data does not support the idea that further road construction... will mitigate that risk”
- “90% of all wildfires start within 1/2 mile of a road”
- “Additional road construction in these areas is likely to increase the risk of fires”
Governance Policy Process
- “need to return to local control of these areas”
- “local decision-making process is far less likely to solicit and value the input”
- “benefits and drawbacks of the change will primarily effect the population making the decision”
Economic Impact Fiscal
- “value of natural resources that might be extracted”
- “temporary economic benefit to the local population”
- “majority of the economic benefit will accrue to the large corporations”

The comment

I am writing to oppose the repeal of the Roadless Area Conservation Rule. The lands affected by this rule are less than 1/4 of the total lands managed by the forest service. As currently managed, the value of these lands in maintaining biodiversity, ecological resilience, and opportunities for people to directly experience nature far outweigh the value of natural resources that might be extracted from them. Furthermore, the bulk of the value returned by resource extraction is likely to occur over just a short few years while significantly degrading the value of the land for biodiversity, ecological resilience, and nature recreation for at least a few decades and possibly much longer depending on subsequent activity in these areas. I also believe that several of the key justifications provided for the proposed rule change are misguided, specifically the risk of wildfires and the need to return to local control of these areas. While wildfires are a significant and growing concern, the data does not support the idea that further road construction in the areas covered by the Roadless Area Conservation Rule will mitigate that risk. Research has shown that 90% of all wildfires start within 1/2 mile of a road and 88% are human-caused. Additional road construction in these areas is likely to increase the risk of fires in them rather than reduce it. The majority of firefighting risk and resulting economic damage from fires occurs in areas containing people and structures. Road constructions will almost certainly increase the number of people and structures in these areas. Finally, given the forest service already manages 370,000 miles of forest roads and estimated the maintenance backlog of current roads at $8.6 billion in 2023, it is unlikely that there will be resources to maintain these roads much less actively manage surrounding lands to reduce wildfire risk. I believe that local control is most appropriate when the benefits and drawbacks of the change will primarily effect the population making the decision. I do not believe that is true in this case. While there may be some temporary economic benefit to the local population from resource extraction in additional jobs, the majority of the economic benefit will accrue to the large corporations managing that activity, who are unlikely to be local. Meanwhile, the overwhelming public support in the comments on this rule when it was originally proposed demonstrated that there are many people with an interest in the management of these lands, myself included, who are not "local" and who would consider further resource extraction a significant drawback. A local decision-making process is far less likely to solicit and value the input of these additional stakeholders. For all of these reasons, I believe the Roadless Area Conservation Rule should not be repealed and should remain in effect.