Comment Analysis · Docket FS-2025-0001

FS-2025-0001-606978

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

  • Water Quality Quantity
    • “watershed and drinking water safety”
    • “drinking water of the United States needs these protected areas to remain safe and clean”
    • “cost of sedimentation due to road runoff would massively impact these already-stressed waters”
    • “water treatment plants and highway departments save up to an estimated $18 Billion from avoiding sedimentation”
  • Environmental Protection Biodiversity
    • “biodiversity and habitat protection”
    • “seven ways that roads affect ecosystems”
    • “destroyed at least 4,784,351 ha of land and water bodies that formerly supported plants, animals, and other organisms”
    • “impossible in any foreseeable future to undo these effects”
  • Recreation Tourism Public Use
    • “recreation opportunities”
    • “protects many of the United States' most valued backcountry recreation areas”
    • “backbone of a $1.3 trillion outdoor recreation economy”
    • “putting at risk: 25,121 miles of trails, 8,659 climbing routes, 768 miles of whitewater”
  • Forest Management Wildfire
    • “wildfire safety”
    • “wildfire-ignition density was lowest in designated wilderness areas”
    • “highest wildfire-ignition density was in lands within 50 meters of roads”
    • “Wildfires are already a massive risk to communities”

What it names

Works cited
10.1046/j.1523-1739.2000.99084.x10.2489/jswc.66.3.78aBarnett and Pierce 2009

The comment

I adamantly am opposed to the revision of the Roadless Rule. I live in North Carolina. I previously have lived in California, Colorado, and New York, all of which have areas currently protected by the Rule. I am concerned in regards primarily to watershed and drinking water safety, wildfire safety, biodiversity and habitat protection, and recreation opportunities. With regards to watershed and drinking water safety: the drinking water of the United States needs these protected areas to remain safe and clean to feed our wells and municipal water reserves. Western states are already struggling to manage sharing water resources. With current trends, streamflow reductions of 10-35% are likely for western states in the next fifty years (Barnett and Pierce 2009). "A 10% drop in streamflow is considered calamitous by municipal water districts." (DellaSala et al., 2011)(https://doi.org/10.2489/jswc.66.3.78A) The cost of sedimentation due to road runoff would massively impact these already-stressed waters. According to the 2011 study by DellaSala et al., water treatment plants and highway departments save up to an estimated $18 Billion from avoiding sedimentation caused by logging in IRA watersheds.(https://doi.org/10.2489/jswc.66.3.78A). With regards to biodiversity and habitat protection, Trombulak et al. (2000) notes the seven ways that roads affect ecosystems: "(1) increased mortality from road construction, (2) increased mortality from collision with vehicles, (3) modification of animal behavior, (4) alteration of the physical environment, (5) alteration of the chemical environment, (6) spread of exotic species, and (7) increased alteration and use of habitats by humans. The 13,107,812 km of road lanes in the conterminous United States have destroyed at least 4,784,351 ha of land and water bodies that formerly supported plants, animals, and other organisms. Direct transfer of sediment and other material to streams and other water bodies at road crossings is an inevitable consequence of road construction. The consequences of past sediment delivery are long-lasting and cumulative and cannot be effectively mitigated." (https://doi.org/10.1046/j.1523-1739.2000.99084.x) Once these roads are built, it is impossible in any foreseeable future to undo these effects. With regards to wildfire safety, the vast majority of fires take place in the areas closest to roads, according to a 2025 study by the Wilderness Society. (https://roadless.org/resources/roads-fire-risk-analysis-2025.pdf) "From 1992 to 2024, in all 8 contiguous-US Forest Service regions combined, wildfire-ignition density was lowest in designated wilderness areas (1.7 fires/1,000 hectares), followed closely by that in Inventoried Roadless Areas (1.9 fires/1,000 ha). The highest wildfire-ignition density was in lands within 50 meters of roads (7.4 fires/1,000 ha), and the second highest wildfire-ignition density was in lands outside of the 100-m road buffers, but not in wilderness or roadless areas (3.5 fires/1,000 ha)." Wildfires are already a massive risk to communities across not only the West and Mountain West, but also across the United States, including in North Carolina. As for recreational opportunities, the Roadless Rule currently protects many of the United States' most valued backcountry recreation areas, which I myself utilize and enjoy frequently. These forests provide clean air and water, fight climate change, and are the backbone of a $1.3 trillion outdoor recreation economy that supports 5.2 million jobs, according to a 2026 Outdoor Alliance white paper. The same paper notes that rolling back the Roadless Rule "could unwind protections for 45 million acres of national forests, putting at risk: 25,121 miles of trails, 8,659 climbing routes, 768 miles of whitewater, 10,794 miles of mountain biking. (https://www.outdooralliance.org/roadless) According to a US Fish & Wildlife Service study on the Izembek Wilderness, "Construction of a road through the existing wilderness and the predicted increase access to the wilderness via all-terrain vehicles (legal and illegal) would result in major impacts to the four indicators of wilderness character: untrammeled quality, natural quality, undeveloped quality, and opportunities for solitude or primitive and unconfined recreation." (https://www.fws.gov/sites/default/files/documents/2024-03/08-chapter-4-environmental-consequences.pdf) The 5000-character limit is insufficient to adequately address the many issues with rescinding the Roadless Rule. These are simply the ways in which it would affect me, personally. I urge every reviewer to take all concerns into consideration above the short-term profits of logging expansion.

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