Opposes rescissionA0 noneSubstance 6/24Posted 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
A0 none: Counted, not answered.
Still open to the agency
Alternative already eliminatedThe agency says it considered and eliminated the alternative the comment proposes, with a reason. Cannot be defeated from the comment text alone.
Already addressedThe 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 decisionThe agency says the point belongs to a later, site-specific decision. Cannot be defeated from the comment text alone.
Misreads the proposalThe agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
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.
No cause and effect shownThe agency says the comment asserts a harm without showing how the action causes it. Defeated when the comment shows the mechanism.
Outside the scopeThe agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.
Certified not substantiveThe agency certifies the comment raises nothing substantive. Defeated when the comment alleges illegality, which is substantive by the definition the certification runs on.
I am writing to oppose the proposal to rescind the Roadless Area Conservation Rule. Rescinding this regulation would allow road construction, reconstruction and timber harvesting in largely unfragmented areas of National Forest that serve as critical habitat for over 300 threatened and endangered species (p. 160).
The introduction of infrastructure to previously roadless areas will not only decrease the health of populations through habitat fragmentation and degradation (road-building and logging decrease soil, water and nutrient quality p. 111, 118, 128) but will also create new entry points for the spread of non-native species, including pathogens, which can have devastating impacts on forests, forest products, and the biodiversity they support (p. 151). The addition of roads of previously roadless areas will also increase the incidence of human-wildlife conflict (p. 151) as well as human-caused fires, with the proportion of human-caused fires in roadless areas often less than half of that in other NDS lands (p. 86, 89; Aplet et al. 2026). Especially in areas with high fuel buildup due to fire suppression activities and inadequate thinning, increased human ignitions will inevitably result in high-severity wildfires that endanger human lives, infrastructure and ecosystems.
Beyond direct impacts on biodiversity, the repercussions of this rescindment may negatively impact fish and game species and cause irreparable damage to the few remaining natural areas that facilitate outdoor recreation and ecotourism (e.g. hunting, fishing, and wildlife viewing) which bring in $1.5 billion/year and $419 million/year, respectively (p. 214). The harvest of timber on currently roadless lands, which is expected to generate $2.2-$11.4 million annually, will not fully compensate for the projected loss of $9 million annually from reductions in recreation and ecotourism, assuming just a 1% loss in visitation (p. 220), nor will they be sufficient to cover the costs of constructing and maintaining new roads associated with this project (p. 45). Finally, rescinding this rule may degrade or reduce access to cultural resources which violates indigenous sovereignty (p. 201-202).
As an professor of Ecology who has recreated and conducted research in roadless federal lands, I am acutely aware of the irreparable damage that will inevitably result from the rescindment of the Roadless Area Conservation Rule, particularly with ongoing reductions to the Endangered Species Act under the current administration. For these reasons, I strongly oppose the rescindment of the Roadless Area Conservation Rule, as this action jeopardizes the ecological and economic functionality of these public lands.