Comment Analysis · Docket FS-2025-0001

FS-2025-0001-255521

Opposes rescissionA0 noneSubstance 5/24Posted August 22, 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

  • Recreation Tourism Public Use
    • “values getting out somewhere that requires effort to reach”
    • “appreciation for solitude, wilderness and connection to nature”
    • “quiet, peaceful recreation”
    • “Hiking in Colorado brought a quietness to my soul”
  • Environmental Protection Biodiversity
    • “Roads change things permanently”
    • “direct loss of habitat (by the conversion of the original land cover into an artificial surface)”
    • “Road mortality is a widely recognized but rarely quantified threat to the viability of amphibian populations”
    • “IRAs increase the size of—and reduce isolation between—protected areas”
  • Water Quality Quantity
    • “road surface erosion and sediment yield”
    • “pollution of off-site waters”
    • “slope failures and mass movement”

What it names

Roadless areas
Rocky MountainWilliams Fork Ptarmingan Adjacent
Works cited
10.1111/cobi.1206310.1111/csp2.28810.1186/1735-2746-10-23

The comment

Dear Secretary: For someone who values getting out somewhere that requires effort to reach, and who has found that value in roadless areas in Colorado, this rule matters in a way that's connected to everything I do outdoors. I lived in Colorado for 3 years and made use of roadless areas year-round. That brought me an appreciation for solitude, wilderness and connection to nature. Although I live in a different part of the country now, I am inspired to find more roadless areas near me to get my fill of that quiet, peaceful recreation. Roads change things permanently. The rule prevents that. Don't rescind it. The whole point of roadless areas is the lack of access and noise. Hiking in Colorado brought a quietness to my soul that I couldn't find elsewhere. It made me aware of the value of the land in this great country of ours, and I mean value as in something worthwhile, not in a monetary sense. Regarding the Williams Fork Ptarmingan Adjacent in the Arapaho & Roosevelt NFs, Colorado: “More than 96% of these areas are located west of the 100[th] meridian, mostly concentrated in northern California, Oregon, Washington, Southeast Alaska, and in Rocky Mountain States. Road construction and reconstruction are already prohibited on 24.2 of the 58.5 million acres of inventoried roadless areas under current land management direction, whereas 34.3 million acres allow road construction and reconstruction. — USDA Forest Service, 2000 (https://www.fs.usda.gov/sites/default/files/roadless/roadless-feis-ssummary.pdf)” “Inadequately constructed forest roads can cause severe environmental impacts including road surface erosion and sediment yield, pollution of off-site waters, slope failures and mass movement, direct loss of habitat (by the conversion of the original land cover into an artificial surface) and indirect loss of habitat (by the fragmentation of an ecosystem into smaller and more isolated patches). On steep terrain, 21% of trees were damaged by excavators and 33% of trees were damaged by bulldozers during forest road construction, and on very steep terrain, 27% of trees were damaged by excavators and 44% of trees were damaged by bulldozers during forest road construction. — Erhan Caliskan, 2013 · Iranian Journal of Environmental Health Science & Engineering (https://doi.org/10.1186/1735-2746-10-23)” “Road mortality is a widely recognized but rarely quantified threat to the viability of amphibian populations. The global extent of the problem is substantial and factors affecting the number of animals killed on highways include life-history traits and landscape features. Secondary effects include genetic isolation due to roads acting as barriers to migration. Long-term effects of roads on population dynamics are often severe and mitigation methods include volunteer rescues and under-road tunnels. Despite the development of methods that reduce road kill in specific locations, there is scant evidence that such measures will protect populations over the long term. — Conservation Biology (Wiley), 2013 (https://doi.org/10.1111/cobi.12063)” “A total of 50.3 million acres of protected wilderness areas, roadless areas, and designated critical habitat, as well as 2,300 miles of wild and scenic rivers are included in the emergency declaration map area, fast-tracking destructive projects in areas that were intentionally set aside to preserve their natural values and functions. — Dr. Dawn Woodard, Dr. Matthew McKinzie, Gabrielle Berthel, 2025 (https://www.nrdc.org/media/what-usdas-emergency-logging-map-gets-dangerously-wrong)” “In 2001, the Roadless Area Conservation Rule prohibited road construction and timber harvest in 240,000 km² of inventoried roadless areas (IRAs) located on United States Department of Agriculture Forest Service lands. Many IRAs are among the most wild, undeveloped areas both in the nation and within their respective states. IRAs increase the size of—and reduce isolation between—protected areas, likely buffering them from external stressors. Formations with the greatest percentage increase in representation when including IRAs in the protected network include Temperate Grassland and Shrubland (57.4%), Cool Temperate Forest and Woodland (52.2%), and Mediterranean Scrub and Grassland (35.5%). — McKinley J. Talty | Kelly Mott Lacroix | Gregory H. Aplet | R. Travis Belote, 2020 · Conservation Science and Practice (https://doi.org/10.1111/csp2.288)” I am so grateful for past administrations for creating and upholding the Roadless Rule so that Americans can be proud of their land and find the peace and recreation they seek. This isn't a close call. Don't rescind. With conviction, CommentID: RLC-20260823-197LA2

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