Comment Analysis · Docket FS-2025-0001

FS-2025-0001-609663

Opposes rescissionA0 noneSubstance 5/24Posted 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

  • Forest Management Wildfire
    • “less than 20% of that land has burned in wildfire”
    • “lowest instances of human-caused wildfire ignitions occur in designated wilderness areas”
    • “protecting our wildland fire infrastructure”
    • “roadless rule (which HAS provisions for roads to be constructed during wildfires”
  • Recreation Tourism Public Use
    • “profits brought by tourism and recreation on our roadless lands”
    • “tourists to roadless areas spent over $8billion”
    • “Parents bring their children to the places their parents brought them”
    • “wonder of White Mountain National Forest”
  • Economic Impact Fiscal
    • “timber harvesting is the primary motivation for the rescission”
    • “profits brought by the timber industry pale in comparison to the profits brought by tourism”
    • “evergeen (pardon the pun) sources of revenue”
    • “lumber cost and access in America are primarily the result of tariff related policies”
  • Environmental Protection Biodiversity
    • “low-severity level that helps to support healthy forest ecology”
    • “protecting... our forests”
    • “opening up some of the 45 million acres to increased road access”
    • “rescission of protections offered these lands”

What it names

National Forests
Gifford Pinchot National ForestWhite Mountain National Forest
Roadless areas
White Mountain

The comment

I strongly oppose the changes being made to the roadless rule outlined in the DEIS. Under the guise of improved access wildland fire and fuels management, the proposal suggests opening up some of the 45 million acres to increased road access. Of those acres, in the past 40 years, less than 20% of that land has burned in wildfire and of that 20% that has burned, roughly half burned at the low-severity level that helps to support healthy forest ecology(Aplet et. al 2026). Evidence supports the lowest instances of human-caused wildfire ignitions occur in designated wilderness areas (woo for 1964 Wilderness Act!) followed roadless areas with higher levels of ignitions correlating with increased proximity to roads. Careless cigarette butts, improperly secured tow chains, lazy campfire management, and intentional arson, all occur more easily with easy road access. This season has seen the USWFS and partner agencies (have your guys at Ag been swept up into that yet or are they still keeping you separate from DOI?) stretched thin under one of the worst wildfire seasons on record. As of writing this comment, we're less than 200,000 acres away from breaking our record for the worst. This pulls red carded staff away from other important jobs, demands disaster resources that are needed for national security, and uproots and ends the lives of Americans throughout the country. By protecting the roadless rule (which HAS provisions for roads to be constructed during wildfires for the purposes of containment and access), we'll be protecting our wildland fire infrastructure, the American people, and our forests. Further, I'm alarmed by the phrasing on page 102 of the DEIS indicating that timber harvesting is the primary motivation for the rescission of protections offered these lands by the roadless rule. Current challenges associated with lumber cost and access in America are primarily the result of tariff related policies. The profits brought by the timber industry pale in comparison to the profits brought by tourism and recreation on our roadless lands. In 2024, tourists to roadless areas spent over $8billion on their recreation implements and in gateway communities. As places are parceled off for timber industry, these people will take their money and seek the experience they had elsewhere or not at all. These are evergeen (pardon the pun) sources of revenue. Parents bring their children to the places their parents brought them and a new customer is introduced to the wonder of White Mountain National Forest in New Hampshire. Or Gifford Pinchot National Forest in Washington or any of the dozens of National Forests I've had the delight of calling my favorite places and that I hope to someday show to my children. If left to the timber lobby, once these places are removed from public access, I think it's reasonable to assume that we cannot get them back. And to the Forest Service staff who might read this: thank you for what you do.

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