Comment Analysis · Docket FS-2025-0001

FS-2025-0001-601638

Opposes rescissionA0 noneSubstance 6/24Posted October 7, 2026 On Regulations.gov

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

A0 none: Counted, not answered.

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

Topics

Water Quality Quantity
- “safeguarding clean drinking water for millions of Americans”
- “directly shield our water quality”
- “protect over 80,000 miles of domestic rivers, naturally filtering out contaminants”
- “secure access to clean fresh water has transitioned from a local conservation issue to a primary metric of national infrastructure resilience”
Environmental Protection Biodiversity
- “preserving old-growth ecosystems”
- “maintaining plant diversity”
- “prevents the severe ecosystem fragmentation that drives habitat loss”
- “threatens undeveloped backcountry ecosystems”
Forest Management Wildfire
- “nearly 90% to 95% of human-caused wildfire ignitions ignite within a half-mile of a road corridor”
- “Introducing new road infrastructure into pristine backcountry exponentially increases fire risks”
- “unroaded areas act as natural, resilient buffers”
- “The justification that rescinding this rule will mitigate wildfire risks is contradicted by existing science”
Scientific Research Evidence
- “Decades of peer-reviewed ecological research further affirm that maintaining the Roadless Rule provides profound, quantifiable scientific benefits”
- “A recent study published in PLOS Water confirms that inventoried roadless areas protect over 80,000 miles of domestic rivers”
- “Forest Service data indicates that non-native, highly flammable invasive plants... are twice as common within 150 meters of a road cut”
- “The Department of Agriculture's own draft environmental impact statement confirms that rolling back these protections threatens... water resources”

The comment

To the United States Forest Service: I am writing to strongly oppose the Department of Agriculture’s proposal to repeal the 2001 Roadless Area Conservation Rule. Intact inventoried roadless areas are critical for safeguarding clean drinking water for millions of Americans, preserving old-growth ecosystems, and supporting robust local outdoor recreation economies. The number of ecological services provided by contiguous wilderness are inumerable. Not to mention the importance for wildlife conservation, maintaining plant diversity, increase erosion risk, buffer against flooding and increase water filtration efficacy. In our region, intact forest ecosystems—like the mature woodlands of the New Jersey Highlands and the critical catchment areas around the Stony Brook, Lower Millstone, and Raritan River watersheds—directly shield our water quality. Undisturbed forest floors prevent heavy sediment erosion, buffer against severe flooding, and keep critical tributaries free from high turbidity and pollutant loads. Beyond the immediate region, contiguous forests in and around the great lakes are critical in maintaining the water qualtiy of the largest fresh water source in the world. As climate disruption and water scarcity accelerate globally, secure access to clean fresh water has transitioned from a local conservation issue to a primary metric of national infrastructure resilience. Allowing industrial development and new road infrastructure to compromise these headwaters weakens the defense-in-depth of our public water grid, introduces long-term economic vulnerability, and degrades a finite strategic asset that cannot be engineered back to health once polluted or disrupted. Decades of peer-reviewed ecological research further affirm that maintaining the Roadless Rule provides profound, quantifiable scientific benefits: • Water Filtration & Grid Resilience: A recent study published in PLOS Water confirms that inventoried roadless areas protect over 80,000 miles of domestic rivers, naturally filtering out contaminants through undisturbed plant roots and forest soils. This green infrastructure supplies clean drinking water to 25 million Americans and lowers chemical treatment costs for downstream municipal utility grids. • Wildfire Mitigation: Spatial data shows that nearly 90% to 95% of human-caused wildfire ignitions ignite within a half-mile of a road corridor. Introducing new road infrastructure into pristine backcountry exponentially increases fire risks, whereas unroaded areas act as natural, resilient buffers. • Biosecurity & Habitat Integrity: Forest Service data indicates that non-native, highly flammable invasive plants (such as cheatgrass) are twice as common within 150 meters of a road cut. Keeping lands roadless prevents the severe ecosystem fragmentation that drives habitat loss and allows biological invasions to degrade native wilderness. The Department of Agriculture’s own draft environmental impact statement confirms that rolling back these protections threatens undeveloped backcountry ecosystems, water resources, and local wildlife corridors. New road construction and logging infrastructure would fragment these fragile habitats, introducing invasive species and The justification that rescinding this rule will mitigate wildfire risks is contradicted by existing science and the Forest Service’s own data. Research shows that human-caused ignitions are significantly more common near roads, and building new infrastructure fragments fragile habitats and invasive species corridors. Furthermore, the Forest Service already manages a multi-billion-dollar road maintenance backlog; adding more unmaintained roads will worsen fiscal and environmental strains rather than alleviate them. I urge the agency to listen to the overwhelming public, tribal, and bipartisan opposition to this repeal and maintain full protections for our remaining backcountry national forest lands. Sincerely, Cara Love