Comment Analysis · Docket FS-2025-0001

FS-2025-0001-604241

Opposes rescissionA0 noneSubstance 4/24Posted 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 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

Economic Impact Fiscal
- “MAINTAINING ROADS IN NATIONAL FORESTS IMPOSES ENORMOUS COSTS ON U.S. TAXPAYERS”
- “backlog of “deferred maintenance” of more than $8.6 billion in FY2023”
- “USFS must pay to maintain the roads”
- “tourist dollars”
Forest Management Wildfire
- “FOREST ROADS CAN INCREASE FIRE RISK”
- “human-ignited wildfires... are more than 5X as likely in roaded than roadless areas”
- “fires are more frequent for decades after logging”
- “increased risk of human-caused fires”
Environmental Protection Biodiversity
- “FOREST ROAD CONSTRUCTION PROMOTES SPECIES INVASIONS”
- “reducing when forest tree regeneration in many national forests”
- “wildlife habitat and biodiversity”
- “Roadless areas offer refugia for wildlife and plant species”
Governance Policy Process
- “RESCINDING THE ROADLESS RULE WILL INCREASE RATHER THAN REDUCE REGULATORY BURDEN”
- “REQUIRING A CONSISTENT NATIONAL POLICY RATHER THAN PATCHWORK INDIVIDUAL FOREST POLICIES”
- “Rescinding the 2001 Roadless Rule contradicts oft-stated cost-saving and efficiency goals”
- “MAINTAINING THE ROADLESS RULE IS CONSISTENT WITH LAWS REQUIRING MULTIPLE-USE FOREST MANAGEMENT”

What it names

Works cited: Balch et al. 2017Mortensen et al. 2009

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

DO NOT RESCIND THE ROADLESS RULE. Reasons offered for rescission are “to reduce regulatory burden” and to “return decision making …to the individual natural forest level.” Neither goal justifies the many harm this will cause. RESCINDING THE ROADLESS RULE WILL INCREASE RATHER THAN REDUCE REGULATORY BURDEN. The Roadless Rule offers clear guidance constraining road construction in designated areas—a rule that applies equally everywhere—thereby REDUCING the regulatory burden. Contrary to the stated goal of reducing regulatory burden, rescinding the rule will actually increase the burden. Requiring that each individual forest consider each new road construction proposal will increase time, effort, and COST. SOME GOALS ARE IMPORTANT ENOUGH TO REQUIRE A CONSISTENT NATIONAL POLICY RATHER THAN PATCHWORK INDIVIDUAL FOREST POLICIES. While “decision making …[at] the individual natural forest level" is reasonable for considering local landscape context, in this case the benefits of the roadless policy are so clear and important—and the potential harms so real and costly—that having a single national “Roadless Rule” is worthwhile. Rescinding the 2001 Roadless Rule contradicts oft-stated cost-saving and efficiency goals of this Administration. There are 4 key reasons to keep the 2001 Roadless Rule. 1. MAINTAINING ROADS IN NATIONAL FORESTS IMPOSES ENORMOUS COSTS ON U.S. TAXPAYERS. Road construction might be paid for by logging contracts but maintenance is not. Even if loggers pay for the construction, USFS must pay to maintain the roads. EXISTING NATIONAL FOREST ROADS ALREADY BILLIONS OF DOLLARS OF DEFERRED MAINTENCE WORK. USFS maintains 200,000 miles of roads for high-clearance vehicles (e.g., logging equipment), 65,000 miles of passenger vehicles roads, and 104,000 miles of roads “stored for future use.” USFS’s own 2023 report (references attached) a backlog of “deferred maintenance” of more than $8.6 billion in FY2023. ADDING NEW ROADS WILL INCREASE MAINTENANCE NEEDS & COSTS, FURTHER TAXING THE U.S. PUBLIC. Roads impose further indirect costs through negative impacts that are hard to calculate but no less significant. USFS (2001) itself reported that forest roads cause harms including debris slides, invasive species, dispersal of pathogens (including tree-harming insects and diseases), water pollution, trash dumping, illegal hunting, and others—including the increased risk of human-caused fires. Sedimentation from road construction affects water quality, fish, and fishing, ultimately harming people (Endicott 2008). Building more roads costs U.S. taxpayers money AND harms human health and recreation. KEEPING THE ROADLESS RULE WILL REDUCE THE BURDEN ON U.S. TAXPAYERS. 2. FOREST ROADS CAN INCREASE FIRE RISK. Roads are touted for fighting wildfires in National Forests, but areas with roads have MORE fires than roadless areas, whether from accident or arson (Syphard 2007, Yang 2007, Narayanaraj et al. 2011, 2012, 2013, Nagy 2018). USFS data (2000) show that forest fires occur nearly twice as often in roaded areas as in roadless areas, and that human-ignited wildfires (which comprise 84% of wildfires, Balch et al. 2017) are more than 5X as likely in roaded than roadless areas. Logging can reduces fuel accumulation and might in some cases reduce fire risk and severity, but that depends on how the logging is done. Many studies show that fires are more frequent for decades after logging, and can be more intense (Furlaud 2021, Levine 2022, Lindenmayer & Sylstra 2024, Lindenmayer 2022, Mackey 2023, Taylor 2014, 2020, 2021, Wilson 2022). 3. FOREST ROAD CONSTRUCTION PROMOTES SPECIES INVASIONS, REDUCING POST-HARVEST TREE REGENERATION—IMPOSING MORE COSTS. Road construction spreads weedy/invasive plant seeds through vehicle tires, construction and logging equipment, and post-construction erosion control materials (Mortensen et al. 2009). Construction-disturbed soils offer ideal beds for invasive plants to root (Jones and Grenz 2023). USFS Forest Inventory data shows that invasive species are reducing when forest tree regeneration in many national forests (Potter et al. 2022). When forests do not regenerate naturally, USFS must spend additional funds on replanting trees. 4. ROADLESS AREAS ARE VALUABLE FOR RECREATION AND BENEFIT LOCAL ECONOMIES WITH TOURIST DOLLARS. The Multiple Use Sustained Yield Act of 1960 and the National Forest Management Act of 1976 require that forests be managed to meet more than just timber demands. Passive (non-motorized) recreation thrives in roadless areas, as does wildlife habitat and biodiversity. Roadless areas offer refugia for wildlife and plant species, and offer sources of new seeds when forest regeneration fails after logging. MAINTAINING THE ROADLESS RULE IS CONSISTENT WITH LAWS REQUIRING MULTIPLE-USE FOREST MANAGEMENT. IN SUMMARY, I URGE YOU TO HALT THE PROPOSAL TO RESCIND THE ROADLESS RULE.