Opposes rescissionA1 strongSubstance 8/24Owed 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.
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A1 strong: Must be answered — it names the law.
Owed an answer on Legal.
Standard dismissals it defeats
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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.
I am writing in strong opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule (36 CFR Part 294, Subpart B; Docket FS-2025-0001). Rescinding blanket protections across 58.5 million acres of Inventoried Roadless Areas (IRAs) threatens headwater drinking supplies, critical fish and wildlife habitat, and vital backcountry recreation, while failing to meet basic legal requirements.
First, the proposal violates the Administrative Procedure Act (5 U.S.C. § 706(2)(A)). Under Motor Vehicle Mfrs. Ass'n v. State Farm, 463 U.S. 29 (1983), an agency reversing course must provide a reasoned explanation supported by empirical facts. When the Tenth Circuit upheld the 2001 Rule in Wyoming v. USDA, 661 F.3d 1209 (10th Cir. 2011), it recognized the agency’s extensive record showing that local, forest-by-forest planning had demonstrably failed to prevent the piecemeal degradation of roadless areas. Citing political directives for timber extraction and "local flexibility" does not overcome this established record.
Second, the rescission ignores the National Environmental Policy Act (NEPA, 42 U.S.C. § 4332). In California ex rel. Lockyer v. USDA, 575 F.3d 999 (9th Cir. 2009), the Ninth Circuit struck down the 2005 State Petitions Rule because the agency failed to conduct a programmatic "hard look" at the cumulative environmental impacts of removing national protections. Shifting management to localized decisions does not excuse the Forest Service from analyzing cumulative fragmentation, erosion, and biodiversity loss.
Third, using wildfire prevention as a justification is fundamentally flawed. The 2001 Rule already allows fuel reduction and small-diameter timber removal to reduce wildfire risks near communities (36 CFR § 294.13(b)(1)). Roads increase human ignitions and fire risk, and building new roads into remote backcountry will only exacerbate the agency’s multibillion-dollar deferred road maintenance backlog, contradicting sustainable management mandates under the Multiple-Use Sustained-Yield Act of 1960 (MUSYA).
Finally, roadless areas serve as essential strongholds for species protected under the Endangered Species Act (ESA) and fulfill diversity requirements under the National Forest Management Act (NFMA, 16 U.S.C. § 1604(g)(3)(B)). Lifting nationwide prohibitions will fracture migration corridors and imperil sensitive populations.
The Forest Service must withdraw this proposal and maintain the established protections of the 2001 Roadless Rule.