Comment Analysis · Docket FS-2025-0001

FS-2025-0001-602579

Opposes rescissionPosted October 7, 2026 On Regulations.gov

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

Topics

  • Scientific Research Evidence
    • “More recent research conducted through Forest Service Research and Development found that roadless areas have not prevented fuel management”
    • “Independent research has also found substantially higher wildfire-ignition density near roads”
    • “The agency's 2001 analysis recognized the wildfire and ecological risks associated with roads”
  • Forest Management Wildfire
    • “allows road construction in inventoried roadless areas when it is needed to protect public health and safety, including in response to an imminent threat of fire”
    • “roadless areas have not prevented fuel management and have not experienced higher rates of fire”
    • “increased density of ignitions near roads”
  • Governance Policy Process
    • “existing exceptions and site-specific processes should continue to be used”
    • “Individual needs do not necessarily justify removing a national protection from millions of acres”
    • “I urge the Forest Service to retain the 2001 Roadless Area Conservation Rule”

What it names

Works cited
10.1186/s42408-026-00450-2Healey 2020Healey 2020

Attachments

1 file. Counts as 1 — Counts as one: The attachments enclose no one else's submissions; the comment counts as one.

  • Own letter

The comment

Please see attached document for my full comments and argument for strongly opposing rescinding the roadless area conservation act. Below is my conclusion from the document. The current roadless area rule already recognizes that there can be exceptional circumstances. It allows road construction in inventoried roadless areas when it is needed to protect public health and safety, including in response to an imminent threat of fire. This means the Roadless Rule does not require the Forest Service to ignore legitimate emergencies or community safety needs. Rather than removing the rule's protections across the board, I believe the existing exceptions and site-specific processes should continue to be used when a particular need can be demonstrated. Individual needs do not necessarily justify removing a national protection from millions of acres. What concerns me most is that some of the justification for rescinding the rule conflicts with the Forest Service's own history and research. The agency's 2001 analysis recognized the wildfire and ecological risks associated with roads (USDA Forest Service, 2001). More recent research conducted through Forest Service Research and Development found that roadless areas have not prevented fuel management and have not experienced higher rates of fire (Healey, 2020). Independent research has also found substantially higher wildfire-ignition density near roads (Aplet et al., 2026). Given that record, I urge the Forest Service to retain the 2001 Roadless Area Conservation Rule. References Aplet, G. H., Hartger, P., & Dietz, M. S. (2026). Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. Fire Ecology, 22, 8. https://doi.org/10.1186/s42408-026-00450-2 Healey, S. P. (2020). Long-term forest health implications of roadlessness. Environmental Research Letters, 15, 104023. https://doi.org/10.1088/1748-9326/aba031 Pew Charitable Trusts. (2026, October 5). U.S. Department of Agriculture proposes eliminating the Roadless Rule. U.S. Department of Agriculture, Forest Service. (2001). Roadless area conservation; Final rule. Federal Register, 66(9), 3244–3272.

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