Comment Analysis · Docket FS-2025-0001

FS-2025-0001-577618

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 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

Forest Management Wildfire
- “Wildfire risk increases with roads: 90% of wildfires begin within half a mile of a road”
- “7.4 fewer fires per 1,000 hectares in roadless areas”
- “An increase in fires would also drain local fire fighting resources”
Economic Impact Fiscal
- “local economic benefit would be minimal”
- “boom-and-bust cycle of development that only benefits the community in the short term”
- “development is likely to occur by a multi state or even international timber or mining company”
Water Quality Quantity
- “protect clean drinking water for American citizens”
- “ransack pristine American waters”
Governance Policy Process
- “states can already tailor the rule as needed”
- “Revision should be the path for local control, following Idaho and Colorado's example”

What it names

Works cited: Healey 2020Healey 2020

The comment

The Roadless Rule should remain in effect. Nothing defines America more than our vast natural forests and rich landscape. While the Rule isn't perfect, lands of such importance require Federal protection, as states can already tailor the rule as needed and any opening in their management would open the door for these spaces to be tainted forever, with little to no economic benefit, and an increase in wildfire risk and further harm to the local region. Rescinding this Rule would not aid in the management of wildfires. Wildfire risk increases with roads: 90% of wildfires begin within half a mile of a road. One study showed that there were 7.4 fewer fires per 1,000 hectares in roadless areas compared to those with roads. Healey 2020 states that it's likely that any benefit gained with more agile positioning of fire-fighting assets is offset by the increase of wildfires that accompanies roads. An increase in fires would also drain local fire fighting resources. Roads increase the presence of invasive plants and trash, ruining the landscape and promoting a cycle of further management. [Healey, Sean P. 2020 Long-term forest health implications of roadlessness. Environmental Research Letters. 15: 104023.] If the roadless rule were rescinded, local economic benefit would be minimal. Consider that development is likely to occur by a multi state or even international timber or mining company, not a local operation, with a boom-and-bust cycle of development that only benefits the community in the short term (ex, look at what happened to Aberdeen WA). "American first" should mean protecting our lands from foreign development as a priority, in stark contrast to what has been allowed to play out in the Boundary Waters of Minnesota, where a Chilean mining company is now slated to ransack pristine American waters that are recreated and enjoyed by Americans. Protecting our lands and leaving the forests in their natural state as opposed to timbering and mining helps stabilize local climates and protect clean drinking water for American citizens. Revision should be the path for local control, following Idaho and Colorado's example. States can already tailor the current rule vs rescind it completely. [Aragon https://www.uwyo.edu/law/centers/center-for-land-and-water-law/blog/long-road-rescinding-roadless-rule.html]