Comment Analysis · Docket FS-2025-0001

FS-2025-0001-604029

Opposes rescissionA3 weakSubstance 9/24Owed an answerPosted October 7, 2026 On Regulations.gov

Small family — One letter sent by 3 to 9 people, copied or lightly reworded. One of 3 submissions in its group; the sender added words of their own. See the letter, its submissions and topics.

In short: The comment places on the record that the proposed rescission of the 2001 Roadless Area Conservation Rule is contradicted by peer-reviewed data showing higher wildfire ignition density near roads, cites California's Natural Resources Agency evidence that roadless protections do not hinder fire management, and identifies specific geographic locations (Wisconsin, California, San Bernardino, Angeles, Cleveland, and Los Padres forests) affected by the rule.

Scored as the letter — The shared letter of a family, scored once for everyone who sent it.

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 Analytical gap, Evidence.

Standard dismissals it defeats

Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
Outside the scope The agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.

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.
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.
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
- “wildfire ignition density is lowest in designated wilderness and inventoried roadless areas”
- “close to 89 percent of wildfires are human caused, and ignitions cluster overwhelmingly near roads”
- “the roadless rule has not hindered active forest management”
- “Roadless areas do not drive the wildfire crisis. Roads do.”
Water Quality Quantity
- “increases sediment and erosion into the watersheds that supply drinking water to millions of Californians”
- “source of the water I drink”
- “watershed and water treatment costs”
Wildlife Habitat
- “opening these areas to road construction and logging fragments wildlife habitat and migration corridors”
- “permanently alters some of the last intact, unroaded forest land left in this state”
Recreation Tourism Public Use
- “spend most of my time in our national forests, hiking, backpacking, and climbing”
- “lost recreation and tourism value”
- “places I go to be outside”

What it names

Roadless areas: Caples Creek

The comment

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

I am writing in strong opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001, RIN 0596-AD66). I live in Wisconsin. While this does not directly affect my home, it would affect me. I often travel and always look forward to the time I get to spend in national forests throughout the US. If the proposed rescission of the 2001 Roadless Area Conservation Rule is approved, the area will not only be harmful to the flora and fauna who call it home, but the areas will be more dangerous due to increased wildfire risks. I am submitting this comment because the stated justification for this rule, reducing wildfire risk, is contradicted by the Forest Service's own research, and I want that contradiction on the record. A peer reviewed study covering three decades of wildfire data across all eight contiguous U.S. Forest Service regions found that wildfire ignition density is lowest in designated wilderness and inventoried roadless areas, and highest within 50 meters of roads, roughly four times higher than in roadless areas. Nationally, close to 89 percent of wildfires are human caused, and ignitions cluster overwhelmingly near roads, since roads are what bring people, vehicles, and ignition sources into the forest in the first place. This is not a matter of interpretation. Roadless areas do not drive the wildfire crisis. Roads do. The proposed rule claims that rescinding roadless protections will give forest managers more flexibility to address wildfire risk. But California's own Natural Resources Agency has stated that the roadless rule has not hindered active forest management, pointing to more than 240,000 acres of roadless land in California that have already undergone vegetation treatment under the existing rule, including work in the Caples Creek roadless area that helped protect communities during the 2021 Caldor Fire. The tools to manage fire risk within roadless areas already exist and are already being used. This rule does not add wildfire protection. It adds roads, and roads are what the data shows increases ignition risk. Beyond fire, opening these areas to road construction and logging fragments wildlife habitat and migration corridors, increases sediment and erosion into the watersheds that supply drinking water to millions of Californians, and permanently alters some of the last intact, unroaded forest land left in this state. Forests including the San Bernardino, Angeles, Cleveland, and Los Padres are not abstract acreage. They are the source of the water people drink. The nature I want to visit will be no more; once they are roaded and developed, that character does not come back. I also have not seen a cost benefit analysis in this proposal that accounts for the increased wildfire suppression costs, watershed and water treatment costs, and lost recreation and tourism value that come with rescinding this protection. Who will pay to keep the roads in pristine condition? Without that, these roads can be dangerous. Already, road upkeep is a challenge for existing roads; adding more does not help anyone. An analysis that omits those costs is incomplete and does not support the conclusion that this rule is a net benefit. Researcher and independent journalist Aidin Robbins made an insightful video about why we need the roadless rule titled “Why We Need the Roadless Rule” which can be found at this link: https://youtu.be/YAH3l0Uzl7k?si=n6foaQhzM4g42YI4. It is credible, with many sources cited. Beyond the points already shared, he showcases different species of creatures, including animals, plants, and moss will likely go extinct if the 2001 Roadless Rule is thoughtlessly removed. Losing species of creatures can impact whole ecosystems beyond repair. Finally, once we start pretending that rules and protections for the dwindling natural resources don’t matter, everyone is in danger. Trees give us oxygen that we need to breathe. Every single person depends on water. Wildfires can destroy homes, health, and large areas of once usable, thriving lands. If this is allowed now, what’s to stop this from happening everywhere? Where does it end? I stand both with the majority of Tribal governments opposed to rescinding the rule and the more than a million supporters of the original adopted rule. I urge the Department to withdraw this proposed rule and keep the 2001 Roadless Rule fully in place. Please enter my opposition into the official record.