Opposes rescissionA0 noneSubstance 5/24Posted 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.
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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
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Misreads the proposalThe agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
Not requiredThe agency says the analysis the comment asks for is not required. Cannot be defeated from the comment text alone.
Preference notedThe 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 shownThe agency says the comment asserts a harm without showing how the action causes it. Defeated when the comment shows the mechanism.
Outside the scopeThe agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.
Certified not substantiveThe agency certifies the comment raises nothing substantive. Defeated when the comment alleges illegality, which is substantive by the definition the certification runs on.
“The concerns of Tribal Nations deserve particular weight”
“substantial Tribal opposition to rescinding the Roadless Rule because of concerns regarding inherent rights, Tribal sovereignty, cultural survival”
“Many contain places with continuing cultural, spiritual, historical, and traditional significance”
The comment
I strongly oppose the proposal to rescind the 2001 Roadless Area Conservation Rule. The National Forest System belongs to the American people, and the remaining roadless lands represent some of the last large, relatively intact forest ecosystems available to the public. These places should be conserved for their ecological, recreational, cultural, and intrinsic values—not opened further to roads, commercial timber extraction, and mineral development.
The argument that rescinding the Roadless Rule is necessary to reduce wildfire risk is particularly concerning because the available evidence does not support it. A recent nationwide study of wildfire ignitions on National Forest lands found that fires, particularly human-caused fires, occur at substantially higher rates near roads than in remote roadless areas and concluded that expanding roads into roadless areas is likely to increase fire ignitions. If wildfire prevention is genuinely the objective, we should be extremely cautious about expanding one of the landscape features most strongly associated with human-caused fire ignition.
There is also little justification for sacrificing some of America's most intact forests in the name of timber production. Roadless areas are not disposable lands waiting to be converted into industrial forests. They provide clean water, wildlife habitat, carbon storage, biodiversity, recreational opportunities, scenic value, and opportunities for people to experience landscapes that remain genuinely wild.
Roadless recreation is not an incidental use of these lands—it is the defining characteristic that makes them valuable. Many Americans deliberately seek places where roads, motor vehicles, heavy equipment, and commercial development are absent. Hiking, backpacking, hunting, fishing, horseback riding, wildlife observation, camping, and simply experiencing solitude are fundamentally different experiences when a person must travel beyond a road rather than having a road constructed into the landscape. Once a road is built, the roadless character of that landscape cannot simply be restored by removing the pavement or closing the gate.
Road construction also has consequences that extend far beyond the physical width of the road itself. Roads fragment habitat, facilitate human access - often with negative outcomes, increase disturbance, introduce invasive species, alter drainage and erosion patterns, and create permanent corridors through otherwise intact ecosystems. Opening roadless areas to mineral extraction would compound these impacts and undermine the very reason these areas were designated for protection.
The concerns of Tribal Nations deserve particular weight. Roadless areas are not simply empty spaces on a map. Many contain places with continuing cultural, spiritual, historical, and traditional significance. The Forest Service's own consultation records indicate substantial Tribal opposition to rescinding the Roadless Rule because of concerns regarding inherent rights, Tribal sovereignty, cultural survival, and the ecological health of ancestral homelands.
Finally, I am deeply concerned about granting this administration additional opportunities to exploit or diminish protected public lands when its recent record provides insufficient reason to trust that ecological, wildlife, and cultural resources will be given priority when they conflict with extraction and development objectives. An administration seeking to remove longstanding conservation safeguards while expanding opportunities for resource extraction should not be given greater discretion over irreplaceable public lands. Trust in public-land management must be earned through stewardship, not assumed in advance.
The American people already possess an enormous amount of developed and roaded forest land. We do not need to turn every remaining remote landscape into another resource-access corridor. Some places should remain difficult to reach. Some forests should remain intact. Some landscapes should remain quiet. And some public lands should exist primarily because their value cannot be adequately measured in board-feet, tons of minerals, or miles of road.
I urge the Department of Agriculture and the U.S. Forest Service to reject the proposal to rescind the 2001 Roadless Area Conservation Rule and retain permanent protections for Inventoried Roadless Areas. These lands belong to all Americans, including generations who have not yet been born. We have a responsibility to leave them with forests, watersheds, wildlife habitat, cultural landscapes, and wild places that are at least as intact as those entrusted to us.