Comment Analysis · Docket FS-2025-0001

FS-2025-0001-584818

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

In short: The comment documents that the DEIS fails to reconcile the agency's claim that roads reduce wildfire risk with its own data (Table 18) showing higher ignition density on roaded lands, and requests evidence on the impacts of rescinding the Roadless Rule on forest health, water quality, biodiversity, and the outdoor recreation economy.

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.

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

Water Quality Quantity
- “protecting clean water”
- “clean our drinking water”
- “More roads leads to more runoff and more pollution”
- “Water clarity is critical for early stages to access sunlight and oxygen”
Wildlife Habitat
- “connected wildlife habitat”
- “critical habitat for wildlife”
- “protect wildlife habitat, biodiversity and migration corridors”
- “manoomin is rapidly disappearing across the heartland's waters”
Recreation Tourism Public Use
- “offer refuge for people seeking quiet and beauty”
- “extremely important to the outdoor recreation community”
- “remove important protections for approximately 45 million acres of back-country national forests”
- “impact rescinding the Roadless Rule will have on outdoor recreation activities”
Cultural Heritage Indigenous
- “Manoomin is an Indigenous cultural touchstone”
- “harvested and enjoyed eating Wisconsin's manoomin”
- “food resource, and keystone wetland plant species”

What it names

National Forests: Shawnee National Forest

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeEA analysisAnalytical gapEvidenceRequest

Dear Secretary Rollins, I am writing in opposition to rescinding the Roadless Area Conservation Rule. For 25 years, the rule has limited permanent road construction and logging in these areas; protecting clean water, connected wildlife habitat, old-growth forests, and places that provide refuge as development consumes more of the landscape. The protections have been particularly vital in the Midwest, where less than 200,000 acres of roadless, untrammeled forest lands survived the widespread logging of the past two centuries. As a lifelong Wisconsin resident, my family and I thoroughly enjoy annual trips to Michigan’s Ottawa Forest as well as countless trips to Wisconsin's Chequamegon-Nicolet Forest, the Shawnee National Forest in Illinois, and many other national forests, national parks and public lands throughout the U.S. The Midwest’s national forests have important roadless areas that provide critical habitat for wildlife, clean our drinking water, store carbon, and offer refuge for people seeking quiet and beauty. For decades my family has harvested and enjoyed eating Wisconsin’s manoomin, a.k.a. wild rice. Clean, fresh water that flows through Wisconsin’s national forests support manoomin. Manoomin is an Indigenous cultural touchstone, food resource, and keystone wetland plant species found primarily in the Great Lakes region. Wild rice significantly influences wetland productivity, pollutant fate, and intricate relationships with various other plant and animal species. However, manoomin is rapidly disappearing across the heartland’s waters. Climate change, land development, and stripped protections threaten “the food that grows on water.” Poor water quality also contributes to manoomin declines. Water clarity is critical for early stages to access sunlight and oxygen. More roads leads to more runoff and more pollution. This will impact manoomin. I am asking the Agency to address my concerns. Wildfire reduction and active forest management The Agency has stated more roads within the roadless areas are necessary to reduce wildfire – a reversal of the agency’s own environmental analysis finding that human-caused ignition density is several times higher on roaded land than in the affected roadless areas. The DEIS shows that the repeal will significantly increase in fire risk. As illustrated in Table 18 in the DEIS, ignition density is nearly four times higher in NFS lands that are not subject to Roadless Rule protections, and the area burned (as a percent of total land area) is also substantially higher on unprotected NFS lands. After nearly 20 years of monitoring data, a 2020 Forest Service Study concluded that more roads do not lead to better forest health through increased fire-management activity. Please explain this reversal. Provide detailed evidence that repealing the Roadless Rule will deliver tangible benefits related to forest health or wildfire risk. Also, provide evidence how repealing these protections may affect other resources, including drinking water and biodiversity, and how climate change may interact and exacerbate the environmental impacts of the proposal. Economic impact The Agency cites the proposal’s own multi-billion-dollar road-maintenance backlog. Repealing the Roadless Rule will ultimately exacerbate this problem because the anticipated revenue from extractive activities “would not be sufficient to cover the costs of constructing and maintaining all new roads related to a project.” Please address how building more roads will address this funding-deprived backlog. Climate changes We have seen increases in extreme temperature, wildfire risk, drought, and insect disease and outbreaks, which the Agency deems as key rationale for the proposed repeal of the Roadless Rule. However, the DEIS does not address the fact that these trends are human-caused. What actions will the Agency take to address human-caused climate change and its effects in future analysis? Outdoor recreation community and outdoor recreation economy The Roadless Rule is extremely important to the outdoor recreation community and the outdoor recreation economy. The rescission would remove important protections for approximately 45 million acres of back-country national forests, including more than 25,000 miles of trails, 10,000 climbing routes, nearly 1,000 miles of whitewater, and more than 10,000 miles of mountain biking. Please include data outlining the impact rescinding the Roadless Rule will have on outdoor recreation activities and outdoor recreation economy. Rescinding the Roadless Rule is unpopular and unnecessary. Experts agree that roadless areas protect wildlife habitat, biodiversity and migration corridors, help keep invasive species at bay, prevent pollution and soil erosion into streams and boost climate resilience. Thank you for considering these comments. Sincerely, Mary