Comment Analysis · Docket FS-2025-0001

FS-2025-0001-260396

Opposes rescissionA0 noneSubstance 6/24Posted August 23, 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
- “protecting headwaters”
- “Roads are major sources of sediment and watershed degradation”
- “Fine sediment degrades aquatic habitat”
- “altered hydrology”
Wildlife Habitat
- “wildlife habitat”
- “intact landscapes”
- “fragment aquatic habitat”
- “reduced fish movement”
Forest Management Wildfire
- “roads increasing wildfire ignitions”
- “humans caused 84% of recorded wildfires”
- “wildfire ignition density... in IRAs versus... within 50 meters of roads”
- “new permanent roads are not a prerequisite for effective wildfire response”
Scientific Research Evidence
- “inconsistent with scientific evidence”
- “Reid and Dunne (1984) found”
- “Motha et al. (2003) found”
- “The scientific record does not demonstrate”

What it names

National Forests: Cibola National Forest Gila National Forest Lincoln National Forest
Roadless areas: Devils CreekEagle PeakFrisco BoxGila BoxLittle Dog And Pup CanyonsLower San FranciscoMeadow CreekOrtega PeakRyan HillSan JoseSouth Guadalupe Mountains

Attachments

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

Own letter

The comment

Re: RIN 0596-AD66; Docket No. FS-2025-0001 To USDA and the U.S. Forest Service: I strongly oppose rescission of the 2001 Roadless Area Conservation Rule and urge USDA to select the No Action Alternative and retain the Roadless Rule. Rescission is inconsistent with scientific evidence concerning roads, watershed health, aquatic habitat, and wildfire risk. New Mexico contains hundreds of thousands of acres of Inventoried Roadless Areas (IRAs) protecting headwaters, wildlife habitat, and intact landscapes. The Gila National Forest alone contains 733,836 acres in 29 IRAs, including Devils Creek, Frisco Box, Eagle Peak, Meadow Creek, Gila Box, Lower San Francisco, and areas adjoining the Gila and Aldo Leopold Wildernesses. Other important IRAs include Ryan Hill, Apache Kid, San Jose, and Datil on the Cibola NF and South Guadalupe Mountains, Little Dog and Pup Canyons, and Ortega Peak on the Lincoln NF. Protecting intact headwaters is particularly important in arid New Mexico. Roads are major sources of sediment and watershed degradation. They compact soils, concentrate runoff, and deliver sediment to streams. Reid and Dunne (1984) found a heavily used gravel road produced approximately 130 times the sediment of an abandoned road, while Motha et al. (2003) found unsealed forest roads produced 20–60 times more sediment per unit area than undisturbed forest. Fine sediment degrades aquatic habitat by filling pools and embedding streambed gravels. Roads and stream crossings also fragment aquatic habitat and alter watershed processes. Jones et al. (2000) documented road effects on hydrology, geomorphology, and stream networks. Warren and Pardew (1998) found culvert and slab crossings reduced fish movement compared with natural stream reaches. This is especially concerning in New Mexico, where perennial aquatic habitat is already limited. USDA's wildfire rationale also fails to account for roads increasing wildfire ignitions. Balch et al. (2017) found humans caused 84% of recorded wildfires in the conterminous U.S. in their 1992–2012 dataset. Aplet et al. (2026), specifically examining National Forest lands, found wildfire ignition density of only 1.97 fires/1,000 ha in IRAs versus 7.99 fires/1,000 ha within 50 meters of roads. Human-caused ignition density within 250 meters of roads was more than three times greater than beyond 500 meters. Building roads into roadless areas therefore risks creating more fires through increased human access. Modern wildfire suppression also does not require permanent roads into every landscape. Smokejumpers, helitack, helicopters, airtankers, hotshots, and other resources allow firefighters, equipment, water, and retardant to reach remote fires. Roads remain useful, but new permanent roads are not a prerequisite for effective wildfire response. The Roadless Rule already provides exceptions for roads needed to address imminent threats from wildfire and other catastrophic events. New roads also create taxpayer liabilities. USDA acknowledges a $6.9 billion deferred-maintenance backlog for existing roads and bridges. Building more roads creates continuing costs for culverts, drainage, erosion repair, stream crossings, and eventual decommissioning. Finally, these National Forests belong to the American public. The original Roadless Rule followed approximately 1.6 million public comments. Public support remains overwhelming: a 2026 national survey reported 76% of likely voters supported the Roadless Rule and only 13% opposed it. These remaining roadless lands are a scarce national resource, not simply acreage awaiting development. I therefore request that USDA withdraw the proposed rescission and select the No Action Alternative, retaining the 2001 Roadless Area Conservation Rule. USDA should fully account for road-related sediment, altered hydrology, aquatic fragmentation, increased human-caused wildfire ignitions, and long-term maintenance costs. The scientific record does not demonstrate that eliminating national Roadless Rule protections is necessary for wildfire management or forest health. Please retain the Roadless Rule and protect these public lands for current and future generations. References: Reid & Dunne (1984), Water Resources Research 20:1753–1761; Motha et al. (2003), Water Resources Research 39; Jones et al. (2000), Conservation Biology; Warren & Pardew (1998), Transactions of the American Fisheries Society 127:637–644; Balch et al. (2017), PNAS 114:2946–2951; Aplet et al. (2026), Fire Ecology 22:8.