Comment Analysis · Docket FS-2025-0001

FS-2025-0001-613157

Opposes rescissionPosted October 7, 2026 On Regulations.gov

Not scored for substance: the comment does not clear the floor of substantive signal.

Topics

  • Environmental Protection Biodiversity
    • “Protected forests harbor precious biodiversity”
    • “77% of roadless areas have potential to conserve threatened & endangered species”
    • “maintaining roadless protections is critical to climate-adaptation connectivity strategies”
  • Public Opinion Support
    • “more than 99.8% of submitters opposed the rescission”
    • “76% of likely voters support the Roadless Rule”
    • “More than 100 members of Congress have co-sponsored the Roadless Area Conservation Act”
  • Recreation Tourism Public Use
    • “Quiet, undeveloped recreation on roadless lands supports local economies”
    • “Spending time in forested areas... fostering my love for science”
    • “I want my kids and the next generation... to have the same access to protected, healthy, biodiverse roadless forests”
  • Scientific Research Evidence
    • “A systematic review of 274 studies found that more than 93 percent documented at least one effect”
    • “Estimates and figures used by the forest service... require correction”
    • “Belote et al., 2016... providing direct evidence that maintaining roadless protections is critical”

What it names

National Forests
Monongahela National ForestSix Rivers National Forest
Roadless areas
Marlin Mountain
Works cited
10.1371/journal.pone.015422310.1371/journal.pone.016725910.5751/es-00528-070205

Attachments

1 file. Counts as 1 — Counts as one: The attachments enclose no one else's submissions; the comment counts as one.

  • Supporting material

The comment

Dear Chief Schultz, Roadless forests in national and state parklands are inherently valuable resources that we have a duty to preserve. Spending time in forested areas like those near where I grew up in Virginia and West Virginia has been hugely influential in fostering my love for science and my appreciation for the complexity and importance of conservation. Protected forests harbor precious biodiversity and in turn provide essential ecosystem services for our future. I have spent countless summer days in Monongahela National Forest in WV, learning about nature, forming friendships, and fostering the confidence and environmental awareness of my peers and younger mentees. The lack of roads or interference from the outside world while experiencing these forests made the lessons learned, adventures had, and bonds formed infinitely more meaningful. I want my kids and the next generation of outdoor educators and workers to have the same access to protected, healthy, biodiverse roadless forests as I had. Regarding the Marlin Mountain in the Monongahela National Forest, West Virginia: Quiet, undeveloped recreation on roadless lands supports local economies through tourism, outfitting, hunting, and fishing. Recreation disturbance has measurable effects on wildlife. A systematic review of 274 studies found that more than 93 percent documented at least one effect of non-consumptive recreation on animals, with 59 percent of those effects classified as negative. Motorized use covers larger spatial extents than non-motorized activities and brings additional disturbance through dust, soil compaction, and vegetation damage. Forest Service leadership has named unmanaged recreation as one of four key threats to national forests (Larson et al. 2016; USDA Forest Service 2016). — Larson et al., 2016 (https://doi.org/10.1371/journal.pone.0167259); USDA Forest Service, Six Rivers National Forest, Gasquet Ranger District, Dece (https://www.nfwf.org/sites/default/files/norcal/Documents/SRNFEIS.pdf) Rescinding the Roadless Rule would open the Marlin Mountain, Monongahela National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. National-scale analysis found 77% of roadless areas have potential to conserve threatened & endangered species... — Loucks et al., 2003 (https://doi.org/10.5751/ES-00528-070205). Estimates and figures used by the forest service in their proposed recission of the roadless rule require correction and more detailed, correct explanation. The thousands if not millions of Americans who support upholding the roadless rule deserve to have their voices heard. The Roadless Rule is one of America's most popular conservation measures, and that support has not faded. Prior to its 2001 enactment, more than 600 public hearings were held nationwide and 1.6 million Americans weighed in to call for protection of these forestlands—more comments than any other federal rule had received at the time. When USDA announced its rescission proposal, the compressed 21-day public comment period in late 2025 drew approximately 600,000 additional comments. A detailed roadless.org analysis of the comment record found that more than 99.8% of submitters opposed the rescission. A February 2026 Pew Charitable Trusts national poll found that 76% of likely voters support the Roadless Rule compared to just 13% opposed, with bipartisan backing from 71% of Republicans, 80% of Democrats, and 80% of independents. More than 100 members of Congress have co-sponsored the Roadless Area Conservation Act of 2025 (S.2042 / H.R.3930) to codify the Rule so it could not be rolled back without an act of Congress. “Unclosed Derivation of the 44.7-Million-Acre Baseline (58.2 less 9 less 4 equals 45.2) The Draft EIS derives the acreage baseline for its entire analysis in a single passage, and the derivation does not close.” “Superseded 58.5-Million-Acre Baseline Stated as Current in the Cost Benefit Analysis; Components Reconcile to Neither Total.” “Identifies the most "natural" (least human-modified) corridors between large protected areas in the U.S. Many of the highest-priority corridors fall within or overlap inventoried roadless areas, providing direct evidence that maintaining roadless protections is critical to climate-adaptation connectivity strategies for wide-ranging species. — Belote et al., 2016 (https://doi.org/10.1371/journal.pone.0154223)” Most respectfully, A Virginian

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