Comment Analysis · Docket FS-2025-0001

FS-2025-0001-613945

Opposes rescissionA3 weakSubstance 8/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment places on the record specific geographic locations (Mt Baker Snoqualmie NF, OkaWen NF) and peer-reviewed scientific data (Aplet et al. 2026, Balch et al. 2017) demonstrating that road construction increases wildfire ignition density and that the Forest Service faces a $15.6 billion deferred maintenance backlog, thereby documenting the commenter's personal stake and the scientific and economic deficiencies in the rationale for rescinding the Roadless Rule.

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

A3 weak: Substantive, but easier to set aside.

Owed an answer on 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

Scientific Research Evidence
- “peer-reviewed science shows the opposite”
- “A 2026 study in Fire Ecology by Aplet, Hartger & Dietz analyzed 32 years of wildfire data”
- “Balch et al., PNAS 2017 found that 84% of all U.S. wildfires are human-caused”
- “Bradley et al., 2016 found forests with higher levels of protection had lower severity values”
Forest Management Wildfire
- “Fires are constantly starting along the national forest roads”
- “No road would have been built where the Little Giant Fire started”
- “building roads into roadless areas is likely to result in more fires, not fewer”
- “Claims that road prohibitions harm forest health are not supported by evidence”
Economic Impact Fiscal
- “Building more roads in national forests would be a drain on taxpayers”
- “deferred-maintenance road backlog was estimated at $8.4 billion”
- “Government Accountability Office has repeatedly flagged Forest Service deferred maintenance”
- “Adding new roads to inventoried roadless areas would only deepen that hole”
Water Quality Quantity
- “streams are beautiful”
- “We need good water in our aquifers and wells”
- “landslides from disturbed soils are a concern”

What it names

Works cited: 10.1002/ecs2.149210.1073/pnas.1617394114Healey 2020

The comment

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

Dear Secretary Rollins and Chief Schultz: As a grandparent, I know the importance of stewardship, not consuming everything but leaving for the next generation what was left for me. We've been taking our grandkids to National Forests and roadless areas since they were very small. My first outdoors photos of my eldest grands were on the Mt Baker side of Stevens Pass, followed by many trips in the Cascades, including the Chiwawa and Chelan area. While my home address may be Mount Vernon, my real home is a cabin outside the Mt Baker Snoqualmie NF, nearby is the OkaWen NF. I step outside and I'm in the forest. I walk a little ways, I'm in the national forest. I'm closer to roadless nf than I am to a super market or hospital. It's a wonderful place for grandkids, grand nieces and nephews to visit. Wildlife is abundant, streams are beautiful. But it's the PNW and landslides from disturbed soils are a concern. Fires are constantly starting along the national forest roads where people drive and camp. No road would have been built where the Little Giant Fire started. And when it burned long enough to escape its valley, it tumbled down the slopes and leapt over the Chiwawa River and then it jumped the nf road. And studies show this, we do not need more roads to stop fires. We need safe slopes so another Oso does not happen. We need good water in our aquifers and wells. Although proponents of rolling back the Roadless Rule claim it is needed for wildfire management, the peer-reviewed science shows the opposite. A 2026 study in Fire Ecology by Aplet, Hartger & Dietz analyzed 32 years of wildfire data across all eight contiguous-U.S. Forest Service regions and found wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads, compared to just 1.97 fires per 1,000 hectares in inventoried roadless areas—a fourfold difference. A separate national analysis (Balch et al., PNAS 2017) found that 84% of all U.S. wildfires are human-caused. Roads are the primary vector for human ignitions, so building roads into roadless areas is likely to result in more fires, not fewer. Building more roads in national forests would be a drain on taxpayers. Even with the Roadless Rule in place, the Forest Service already has a 380,000-mile road system—twice as long as the U.S. highway system—crisscrossing national forests. The agency cannot afford to maintain it: the deferred-maintenance road backlog was estimated at $8.4 billion in the 2001 Final Environmental Impact Statement and is roughly $15.6 billion in today's dollars. The Government Accountability Office has repeatedly flagged Forest Service deferred maintenance as one of the largest in the federal government, and the backlog has never dropped below $5 billion. Adding new roads to inventoried roadless areas would only deepen that hole. “A national analysis of two decades of wildfire data found that human-started wildfires accounted for 84% of all wildfires, tripled the length of the fire season, and were responsible for nearly half of all area burned. Because roads are the primary vector for human ignitions, the finding directly bears on the wildfire consequences of opening roadless areas to road construction. — Balch et al., 2017 (https://doi.org/10.1073/pnas.1617394114)” “Comparing fire severity across forests under different protection regimes, the study found forests with higher levels of protection had lower severity values even though they are generally identified as having the highest overall levels of biomass and fuel loading. The result contradicts the claim that protected, intact forests are more dangerous fire risks. — Bradley et al., 2016 (https://doi.org/10.1002/ecs2.1492)” “National monitoring analysis using ~20 years of data found forests in roadless areas burned at similar frequencies as roaded areas. Claims that road prohibitions harm forest health are not supported by evidence. — Healey, 2020 (https://doi.org/10.1088/1748-9326/aba031)” A rule that has survived multiple administrations and multiple rounds of circuit-court review should not be rescinded on the present record. CommentID: RLC-20261006-SLBYA0