Comment Analysis · Docket FS-2025-0001

FS-2025-0001-603822

Opposes rescissionA3 weakSubstance 8/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment places on the record specific statistical data from the National Interagency Fire Center regarding wildfire ignition density near roads versus in roadless areas in Arizona, along with historical public comment volumes, to argue that rescinding the Roadless Rule would significantly increase wildfire risk and degrade wildlife habitat.

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

A3 weak: Substantive, but easier to set aside.

Owed an answer on Evidence.

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

Forest Management Wildfire
- “rescinding the rule would increase fire risk in backcountry forests”
- “fires are 4x more likely to start near a road than in a roadless forest”
- “The Roadless Rule helps protect areas that are fire resilient”
- “We cannot afford to increase our wildfire risk by 4-fold”
Wildlife Habitat
- “impair habitat for sensitive species and degrade our most intact and resilient ecosystems”
- “critical habitat for threatened and endangered species like the Mexican spotted owl, Apache trout and jaguar”
- “Opening roadless areas to logging and road-building will create more degraded and fragmented habitat”
Public Opinion Support
- “This proposal ignores the will of the American public”
- “over 99% of comments urging that the Roadless Rule be retained”
- “received well over a million public comments supporting the rule”
Recreation Tourism Public Use
- “As an avid outdoors person and concerned citizen”
- “inability to access important local recreational areas”
- “1.174 million acres in Arizona where I live and recreate”

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequestAlternative

As an avid outdoors person and concerned citizen from Arizona, I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. This proposal would remove protections for 45 million acres of the wildest and most intact public lands across our National Forests, including 1.174 million acres in Arizona where I live and recreate. It would allow road construction, development, and commercial logging in currently protected Inventoried Roadless Areas. Particularly of concern to me it that rescinding the rule would increase fire risk in backcountry forests. The area near where I live has been beset by numerous forest fires in recent years. The economic, environmental and social effects of these forest fires can be devastating. For me personally, frequent forest fires have resulted in being unable to open any windows or go outside without wearing an N-95 for weeks on end due to horrible local air quality, concerns that I or friends and co-workers might have to evacuate, inability to access important local recreational areas, potentially indefinitely and increased flooding locally. The Roadless Rule helps protect areas that are fire resilient and less prone to wildfire ignitions. Studies show that fires are 4x more likely to start near a road than in a roadless forest, and logging can increase fire hazard. Publicly available data from the National Interagency Fire Center shows that since 1992, there have been over 8,000 fires that started within 100 meters of a road in Arizona, 6x greater than the number of fires that have started in roadless areas during the same timeframe. The density of wildfire ignitions within 100 meters of a road is also much greater than within roadless areas, with over 18 wildfire ignitions per 1,000 hectares compared to 3 per 1,000 hectares in roadless areas. Arizona continues to grapple with frequent wildfires amid historic drought conditions. We cannot afford to increase our wildfire risk by 4-fold. This proposal would also impair habitat for sensitive species and degrade our most intact and resilient ecosystems. Roadless areas provide some of the last best habitat areas that are still developing under the natural processes and landscape patterns that wildlife evolved with. Many of these areas in Arizona serve as critical habitat for threatened and endangered species like the Mexican spotted owl, Apache trout and jaguar. Opening roadless areas to logging and road-building will create more degraded and fragmented habitat that is already vastly over-abundant. This proposal ignores the will of the American public. When the Clinton Administration first proposed the Roadless Rule back in 2000, it received well over a million public comments supporting the rule, more than any administrative proposal in US history at the time. When the Trump Administration initially proposed rescinding the Roadless Rule last September, over 600,000 Americans submitted public comments, with over 99% of comments urging that the Roadless Rule be retained. For the reasons listed above, fully or partially rescinding the Roadless Rule under Alternatives 2 and 3 of the draft EIS would be a grave mistake. I oppose the proposal to rescind or alter the Roadless Rule and support Alternative 1, the No Action alternative.