Comment Analysis · Docket FS-2025-0001

FS-2025-0001-577716

Opposes rescissionA2 moderateSubstance 12/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment documents that the agency's Draft EIS acknowledges increased wildfire ignition probability with road density, cites research (Aplet et al., 2026) showing fires are four times more likely near roads, and argues that the proposed rescission of the 2001 Roadless Rule is unsupported by the evidence and contradicts the goal of fire risk reduction.

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

A2 moderate: Hard to dismiss — it shows cause and effect.

Owed an answer on Analytical gap, Evidence.

Standard dismissals it defeats

Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
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.

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.
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.
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

Recreation Tourism Public Use
- “quiet, undeveloped backcountry experience”
- “rock climber and Mountaineers volunteer”
- “recreational values the 2001 rule was created to protect”
Forest Management Wildfire
- “skeptical of the wildfire rationale”
- “probability, number, and frequency of wildfire ignitions”
- “fires are four times as likely to start near roads”
Environmental Protection Biodiversity
- “habitat connectivity”
- “watershed integrity”
- “lost for generations”

What it names

Roadless areas: Middle Fork

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequestAlternativeLegal

I am writing to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (FS-2025-0001 / RIN 0596-AD66) and urge the Forest Service to retain the rule in full. I am a rock climber and Mountaineers volunteer living in Snoqualmie, Washington. My climbing and backcountry travel take me through the national forests of the Cascades, including the Middle Fork and the I-90 corridor — areas whose character depends directly on roadless protections. The quiet, undeveloped backcountry experience I seek is only possible because these landscapes are not laced with roads. I am skeptical of the wildfire rationale for this rescission. The agency's own Draft Environmental Impact Statement acknowledges that as road density increases, so do the probability, number, and frequency of wildfire ignitions — and recent research (Aplet et al., 2026) finds fires are four times as likely to start near roads. If the goal is reducing fire risk, building more roads into roadless areas works against it. The rule's exceptions already allow hazardous-fuel treatments where genuinely needed; the claim that local managers are blocked is not a case for eliminating protections across 44.7 million acres. Roads are effectively permanent. Once built, the habitat connectivity, watershed integrity, and recreational values the 2001 rule was created to protect are lost for generations — and the agency's deferred maintenance backlog shows it cannot manage the roads it already has, let alone tens of thousands of new miles. The burden of proof is on rescission, and it has not been met. Please retain the Roadless Rule in full.