Comment Analysis · Docket FS-2025-0001

FS-2025-0001-579282

Opposes rescissionA2 moderateSubstance 13/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment establishes that the DEIS and cited scientific studies contradict the agency's justification for rescinding the Roadless Rule by demonstrating that roads increase wildfire ignition density and that roadless areas provide critical water and habitat services, thereby supporting the retention of the existing rule.

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

  • Forest Management Wildfire
    • “The main justification for rescinding the rule, that more roads are needed to reduce wildfire risk, is not supported by scientific research”
    • “Science clearly shows that roads are the dominant place where fires start and adding more roads will increase fire risk”
    • “Burning government time and money on building more roads and logging in our country's most intact, backcountry forests will worsen wildfire risk”
  • Water Quality Quantity
    • “clean drinking water”
    • “IRAs protect watersheds that supply drinking water to over 25 million Americans”
    • “IRAs are critical drinking-water infrastructure for the American people”
  • Wildlife Habitat
    • “critical wildlife habitat”
    • “connecting habitat for wildlife”
    • “conserving the highest integrity forests in the US”
  • Economic Impact Fiscal
    • “The Forest Service can't afford to take care of the roads it already has and runs an over $10.8 billion deferred maintenance backlog”
    • “adding even more roads that are expensive to build and costly to maintain in remote areas is grossly uneconomic”
    • “Fiscal considerations of building additional roads were a major concern and rationale for the 2001 Roadless Rule”

What it names

Works cited
10.1016/j.biocon.2026.11195010.1186/s42408-026-00450-210.1371/journal.pwat.0000538

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeAnalytical gapEvidenceRequestLegal

October 5, 2026 Dear Director, Ecosystem Management Coordination Comments on docket number FS-2025-0001-223869, Special Areas: Roadless Area Conservation I support the “no action” Alternative 1, and oppose any proposal that fully or partially rescinds the Roadless Area Conservation Rule. The rule is one of the most important land conservation policies in our nation, conserving the highest integrity forests in the US.[1] The Roadless Rule has proven its effectiveness through the many values these areas provide, clean drinking water, critical wildlife habitat and carbon storage in mature and old-growth forests, cultural values, increased human health, and world class recreation. IRAs provide these valuable and irreplaceable ecosystem services free of cost. I live in Northeast Oregon, where Roadless Areas play an integral role in connecting habitat for wildlife and providing places for recreation for our family and our community. The main justification for rescinding the rule, that more roads are needed to reduce wildfire risk, is not supported by scientific research or the DEIS. Science clearly shows that roads are the dominant place where fires start and adding more roads will increase fire risk. In a study of three decades of fire ignitions, wilderness and roadless areas had the lowest ignition densities, while areas near roads had the highest wildfire ignition density because people start the most fires.[2] The DEIS's own analysis found that “The total number of wildfires originating on NFS lands from 2014 to 2024 is lowest within wilderness, followed by potentially affected IRAs, and highest on other NFS lands (Table 18).” At 101 the DEIS states that “With increased road construction, especially open-access roads, and other human activity, there could be increased hazard from human-caused ignitions.” Burning government time and money on building more roads and logging in our country's most intact, backcountry forests will worsen wildfire risk. The Forest Service can't afford to take care of the roads it already has and runs an over $10.8 billion deferred maintenance backlog mostly due to roads.[3] Fiscal considerations of building additional roads were a major concern and rationale for the 2001 Roadless Rule. With road maintenance costs already on the rise, adding even more roads that are expensive to build and costly to maintain in remote areas is grossly uneconomic. Roadless areas provide many valuable services that are degraded by road-building like clean drinking water. A recent study found that IRAs protect watersheds that supply drinking water to over 25 million Americans.[4] One-third of the populations of Colorado, New Mexico, and Montana source drinking water to IRA-influenced watersheds, and eastern US IRAs are smaller, but disproportionately important because of their proximity to large urban centers. IRAs are critical drinking-water infrastructure for the American people. Scientific research and the DEIS show that the justifications for rescinding the Roadless Rule are wrong. I support alternative 1 and respectfully urge you to leave the Roadless Area Conservation Rule unchanged. Sincerely, Andrea Mildrexler [1] Mildrexler, D.J.; Berner, L.T.; Law, B.E.; Booth, M.S. Roadless Rule Rescission Threatens Highest Integrity Forest Ecosystems in the United States. Biol. Conserv. 2026, 321, 111950. https://doi.org/10.1016/j.biocon.2026.111950 [2] Aplet, G.H., Hartger, P., and Dietz, M.S. (2026). Three-decade record of contiguous-US national forest wildfires indicates increased density of ignition near roads. Fire Ecol. 22, 8. https://doi.org/10.1186/s42408-026-00450-2 [3] USDA Forest Service (2025b). Fiscal Year 2025, Quarter 2 Deferred Maintenance Needs. https://www.fs.usda.gov/sites/default/files/fy25-q2-deferred-maint-report.pdf. [4] Olden JD, Postel SL, Dombeck MP, Kesting H, Freeman P, Comte L (2026) Assessing the value of the U.S. Roadless Rule for people and nature. PLOS Water 5(7): e0000538. https://doi.org/10.1371/journal.pwat.0000538

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