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.
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 eliminatedThe agency says it considered and eliminated the alternative the comment proposes, with a reason. Cannot be defeated from the comment text alone.
Already addressedThe 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 decisionThe agency says the point belongs to a later, site-specific decision. Cannot be defeated from the comment text alone.
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.
“surmounting problems with our current infrastructure”
What it names
Works cited
10.1186/s42408-026-00450-2Healey 2020
The comment
Hello, I am Sarah Zito and I oppose the recission of the 2001 Roadless Area Conservation Rule.
I currently reside in the state of Washington, and prior to that, I lived in California. Both states are known for their astounding variety of biomes and public lands, including forests. I grew up camping, hiking, and backpacking in many of those forests, and now travel throughout the country to visit forests in other states. While I do use roads to get there, we do not need to add more to the ones already in existence. Many of our most scenic lands have limited or no road access, helping them to remain unspoiled and pristine.
One of the main arguments for repealing the Roadless Area Conservation Rule is to allow the construction of roads to increase access for fire mitigation, but this is entirely unnecessary as Section 294.13 already permits tree thinning and emergency fire access.
Another study, conducted by the US Forest Service, published in 2020 analyzed 20 years of data and found that, “…a lack of roads has not stopped fire prevention measures…” (Healey, Sean P. 2020 Long-term forest health implications of roadlessness. Environmental Research Letters. 15: 104023). This same study also found that, “roads are strongly associated with the spread of invasive plant species in national forests.” The conclusion of that study is that, “Speculation that eliminating road prohibitions would improve forest health is not supported by nearly twenty years of monitoring data.” In another paper, published this year, it was found that, “wildfire-ignition density was lowest in designated wilderness areas.” (Aplet, G.H., Hartger, P. & Dietz, M.S. Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. fire ecol 22, 8 (2026). https://doi.org/10.1186/s42408-026-00450-2)
Other impacts of building roads include but are not limited to the disruption of migratory routes, habitat fragmentation, deforestation, increased roadkill, the loss of biodiversity, the easier spread of invasive organisms, and an increase in air, soil, and water pollution. As an actual scientist with a background in environmental sciences and toxicology, ALL of those reasons should be concerning to EVERY person in this country, especially to those who are contemplating removing safeguards to increase these negative impacts. The destruction of our natural resources is definitely concerning to many voters, and those voters may choose to oust an elected representative who chooses to support abolishing this rule.
Aside from the environmental impacts, there are also potential economic impacts to consider, such as who will be paying for these roads? If it a private corporation, will the public even be granted access to the roads? And if public lands are placed into the hands of a private corporation, will there be compensation to the general public? If the roads are paid for by our tax dollars, how will funds be allocated? We already have surmounting problems with our current infrastructure and existing roads need to be serviced before we even contemplate making additional ones.
The Forest Service should choose the No Action Alternative, keeping this rule fully intact.
Thank you,
Sarah Zito