Comment Analysis · Docket FS-2025-0001

FS-2025-0001-592306

Opposes rescissionA1 strongSubstance 10/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment establishes that the DEIS's rationale for rescinding the Roadless Rule is flawed because the cited management needs are already permitted under the current rule, and it documents that road proximity increases wildfire ignition density while road maintenance backlogs make decommissioning more cost-effective than maintenance, supporting the selection of Alternative 1 (No Action).

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

A1 strong: Must be answered — it names the law.

Owed an answer on Analytical gap, Evidence, Legal.

Standard dismissals it defeats

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.
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.
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.

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.
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.

Topics

Governance Policy Process
- “totally inadequate 21-day “predecisional” comment period”
- “Any attempt to revoke the rule should provide at least as much opportunity for public comment”
- “Executive Order 14225... arbitrarily requires the national forests to increase their harvest levels”
- “highly disingenuous for the current administration to claim the Roadless Rule precludes local decision making”
Forest Management Wildfire
- “USFS erroneously claims that rescinding the Roadless Rule... will reduce wildfire risk”
- “ignition density was lowest in designated wilderness areas... followed closely by Inventoried Roadless Areas”
- “highest ignition density was on lands within 50 m of roads”
- “decommissioning is far more cost-effective than maintaining unneeded roads”
Legal Regulatory Framework
- “KEEP THE 2001 ROADLESS RULE!”
- “Alternative 1 (“No Action”) is clearly the most environmentally and fiscally responsible alternative”
- “boundary modification can be accomplished through rulemaking, without revoking the Roadless Rule”
- “Please choose Alternative 1 and keep the Roadless Rule”
Economic Impact Fiscal
- “typical costs for annual road maintenance can range from $5,000 to $50,000 per mile”
- “deferred maintenance backlog was estimated at $8.4 billion... increased to over $10.8 billion”
- “decommissioning costs are comparable to a year of maintenance”
- “most environmentally and fiscally responsible alternative”

What it names

Law cited: EO14154 Executive Order 14225

The comment

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

KEEP THE 2001 ROADLESS RULE! BACKGROUND In October 1999, then-President Clinton announced an effort to address the 58.5 million acres of Inventoried Roadless Areas (IRAs) in our national forests. The proposed Roadless Rule would limit road construction and timber harvest, address the deferred maintenance backlog, and provide lasting protection for these areas. Over the next year, the Forest Service held over 600 public hearings across the nation. Over 1.6 million comments were submitted, nearly 97% in favor of the rule. Now the USFS is proposing to rescind the rule with a totally inadequate 21-day “predecisional” comment period and 47-day comment period for the Draft Environmental Impact Statement (DEIS). Any attempt to revoke the rule should provide at least as much opportunity for public comment as when the original rule was proposed. FLAWED RATIONALE The DEIS claims Roadless Rule rescission is needed for “management flexibility” and to promote “decisionmaking by local Forest Service officials” (p10). It also claims rescission is needed to “allow for active management to respond to changing and localized conditions, such as increasing wildfire risk, the spread of insect and disease infestations, and the need for community protection in the wildland-urban interface.” Yet as explained in the DEIS, all these activities are already allowed under the current rule. The DEIS (p12) disparages the rule for being “one size fits all”. However, Executive Order 14225 (“Immediate Expansion of American Timber Production”) arbitrarily requires the national forests to increase their harvest levels by 25%, while EO14154 arbitrarily directs them to accommodate the wishes of the fossil fuel industry. It is highly disingenuous for the current administration to claim the Roadless Rule precludes local decision making while issuing blanket executive orders that allow for no local input. Indeed the DEIS (p10-11) all but states that the proposed rescission is aimed at ramping up road building and timber harvest in IRAs. Under Alternative 3 two types of land would be removed from IRAs - non-national forest system lands included under the rule due to mapping errors, and Congressionally designated areas, which have more restrictive and permanent mandates than the Roadless Rule. As pointed out in Table 2 though, boundary modification can be accomplished through rulemaking, without revoking the Roadless Rule. ROADS According to the DEIS: “…less than 10 percent of paved roads and less than 30 percent of gravel roads are in good condition.” (p40) “…typical costs for annual road maintenance can range from $5,000 to $50,000 per mile. A review of route decommissioning costs..indicated [costs] from as low as $2,000 per mile for minor treatments...to an excess of $50,000 per mile for more complex treatments”(p41). “…the Forest Service received approximately $270 million in fiscal year 2023, or less than 20 percent of the estimated funding needed to maintain its existing road infrastructure.”(p42). “Annual appropriations for construction, improvement and maintenance of the road system have drastically declined” from $234 million in 2004 to $73 million 2024 (p43). “In 2001, the deferred maintenance backlog was estimated at $8.4 billion for all maintenance levels of roads.” (p43). This has increased to over $10.8 billion in 2025 (USDA-FS. FY2025, Q2 Deferred Maintenance Needs). “The Forest Service has a significant road maintenance backlog; however, it is assumed that some new road construction and additional maintenance would result from any action alternative.”(p45) These are all compelling reasons for MAINTAINING THE CURRENT ROADLESS RULE, not revoking it. As stated in the DEIS, decommissioning costs are comparable to a year of maintenance, so decommissioning is far more cost-effective than maintaining unneeded roads. FIRE The USFS erroneously claims that rescinding the Roadless Rule and allowing road building in IRAs will reduce wildfire risk. A recent study of the impacts of roads on wildfire ignition density across all 8 contiguous USFS regions (Aplet et al 2026. Fire Ecology 22, article 8) found that from 1992 to 2024, ignition density was lowest in designated wilderness areas (1.75 fires/1000 ha), followed closely by Inventoried Roadless Areas (1.97 fires/1000 ha).The highest ignition density was on lands within 50 m of roads (7.99 fires/1000 ha), and the second highest density was on other national forest lands outside of the 50-m road buffers but not in wilderness or roadless areas (3.50 fires/1000 ha). Lands between 0 and 250 m from roads averaged 6 ignitions/1000 ha, while lands over 2000 m from roads averaged fewer than 2 ignitions/1000 ha. CONCLUSION The 2001 Roadless Rule has worked well for 25 years. Alternative 1 (“No Action”) is clearly the most environmentally and fiscally responsible alternative. Please choose Alternative 1 and keep the Roadless Rule.