Comment Analysis · Docket FS-2025-0001

FS-2025-0001-572888

Opposes rescissionPosted October 6, 2026 On Regulations.gov

Not scored for substance: the comment does not clear the floor of substantive signal.

Topics

  • Climate Carbon Storage
    • “highest carbon storage”
    • “impairs core ecosystem functions including biomass production, nutrient cycling, and carbon storage”
    • “Intact canopy moderates temperature”
  • Environmental Protection Biodiversity
    • “greatest ecological resilience”
    • “Fragmentation by roads reduces biodiversity by 13 to 75 percent”
    • “threatens the very survival of many native plants and animals”
  • Wildlife Habitat
    • “many animals and plants depend on natural treefall and undisturbed areas”
    • “could introduce non-native invasive species”
    • “roadless condition is not what makes these lands vulnerable to disturbance”

What it names

Works cited
Haddad et al. 2015

The comment

"Primary forests with the least disturbance history have the highest carbon storage, greatest ecological resilience, and the lowest risk of loss and damage (Rogers et al. 2022). Intact canopy moderates temperature, with the cooling effect strongest in hot and dry years — precisely when species need it most (Thom et al. 2020; Xu et al. 2022). Fragmentation by roads reduces biodiversity by 13 to 75 percent across studied ecosystems and impairs core ecosystem functions including biomass production, nutrient cycling, and carbon storage (Haddad et al. 2015). The roadless condition is not what makes these lands vulnerable to disturbance — it is what makes them resilient to it." Additionally, may animals and plants depend on natural treefall and undisturbed areas to survive. Cutting roads through these areas threatens the very survival of many native plants and animals and could introduce non-native invasive species to the area.

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