Comment Analysis · Docket FS-2025-0001

FS-2025-0001-585186

Opposes rescissionPosted October 6, 2026 On Regulations.gov

Not scored for substance: the comment does not clear the floor of substantive signal.

Topics

  • Forest Management Wildfire
    • “wildfire ignition density within 50 meters of roads is roughly four times higher”
    • “Wilderness and Inventoried Roadless Areas have the lowest ignition densities”
    • “Most ignitions near roads are human-caused”
  • Climate Carbon Storage
    • “Primary forests with the least disturbance history have the highest carbon storage”
    • “Fragmentation by roads... impairs... carbon storage”
    • “Intact canopy moderates temperature”
  • Environmental Protection Biodiversity
    • “Fragmentation by roads reduces biodiversity by 13 to 75 percent”
    • “impairs core ecosystem functions including biomass production, nutrient cycling”
    • “degradation of resource values and exacerbation of environmental harms”
  • Economic Impact Fiscal
    • “Counties with substantial protected federal lands have grown faster in population, employment, and per capita income”
    • “Wilderness recreation generates an estimated $574 million annually”
    • “Expanding the road network... would compound this maintenance burden”

What it names

Works cited
Haddad et al. 2015

The comment

A 2026 study of three decades of National Forest System wildfire data found that wildfire ignition density within 50 meters of roads is roughly four times higher than in non-wilderness, non-roadless forest. Wilderness and Inventoried Roadless Areas have the lowest ignition densities of any land category studied (Aplet et al. 2026). Most ignitions near roads are human-caused. Primary forests with the least disturbance history have the highest carbon storage, greatest ecological resilience, and the lowest risk of loss and damage (Rogers et al. 2022). Intact canopy moderates temperature, with the cooling effect strongest in hot and dry years — precisely when species need it most (Thom et al. 2020; Xu et al. 2022). Fragmentation by roads reduces biodiversity by 13 to 75 percent across studied ecosystems and impairs core ecosystem functions including biomass production, nutrient cycling, and carbon storage (Haddad et al. 2015). Research on Western U.S. economies describes a shift from extraction-based growth to amenity-based growth. Counties with substantial protected federal lands have grown faster in population, employment, and per capita income than counties without — with growth concentrated in lodging, dining, and professional services (Izon et al. 2010; Holmes & Hecox 2002). Wilderness recreation generates an estimated $574 million annually in economic value, and Western wilderness passive-use value is estimated at roughly $168 per acre (Loomis 2000). The Forest Service's own road-management strategy documents an $8.4 billion deferred maintenance backlog across the existing road network — a backlog the agency has acknowledged it cannot resolve. Expanding the road network into roadless areas would compound this maintenance burden (USDA Forest Service 2001 EA). The repeal of the Roadless Rule will result in degradation of resource values and exacerbation of environmental harms.

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