Comment Analysis · Docket FS-2025-0001

FS-2025-0001-275469

Opposes rescissionA3 weakSubstance 12/24Owed an answerPosted August 27, 2026 On Regulations.gov

Small family — One letter sent by 3 to 9 people, copied or lightly reworded. This comment stands for 4 submissions in its group; the sender added words of their own. See the letter, its submissions and topics.

In short: The comment establishes that the DEIS fails to project the specific impacts of habitat fragmentation, big game population effects, and carbon storage changes across the 40.1 million affected acres, despite citing data indicating significant biodiversity loss, reduced elk survival on roads, and substantial carbon storage in roadless areas.

Scored with own additions — A family member whose own text beyond the shared letter was scored and combined with the letter's score.

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 Analytical gap.

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

Wildlife Habitat
- “seen and taken photos of bear, moose, elk, deer and attempting photos of raptors”
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
- “elk survival rates increased during a road closure and decreased when the gates were removed”
- “elk avoid roads and select unroaded habitat”
Water Quality Quantity
- “clean water and clean air”
- “We need our watersheds to be a high priority for the Forest Service and BLM”
- “Logging and the extractive industries present too high of a risk to this valuable resource”
- “decades long drought out west and the way our distribution of water is managed has caused the disastrous current position in a water crisis”
Climate Carbon Storage
- “standing forests where I watch wildlife are doing quiet work the whole time, holding carbon”
- “inventoried roadless areas contain about 5 percent of the stored forest carbon in the coterminous United States”
- “quantify the change in carbon storage and sequestration under each alternative”
Recreation Tourism Public Use
- “I enjoy the solitude, the scenic landscapes and the wildlife”
- “endless opportunities for hiking and camping”
- “It would be a devastating sight for me if a new forest road is added to this area”
- “We have thousands of Forest Roads already - there is no need to add any more”

What it names

National Forests: San Juan National Forest

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapEvidenceLegal

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 While hiking in wilderness quality lands the last few years, I have seen and taken photos of bear, moose, elk, deer and attempting photos of raptors. The Western Slope in Colorado have endless opportunities for hiking and camping. I enjoy the solitude, the scenic landscapes and the wildlife - and just getting far off into the forest. The public lands out west have an abundance of valuable resources that provide for the local communities - recreation, clean water and clean air, hunting, fishing. These resources are vital to our communities and should be managed as such. Too much emphasis has been placed on the extractive industries which run counter to the resources mentioned above. I have a young daughter, and I feel we are not going to leave a valuable legacy to our kids of these public lands that need protection. The decades long drought out west and the way our distribution of water is managed has caused the disastrous current position in a water crisis out west. We need our watersheds to be a high priority for the Forest Service and BLM. Logging and the extractive industries present too high of a risk to this valuable resource. Living out west the last 30 years, I have experienced many wildfire events. A few of these have put me on evacuation notices; and many from all over the west has caused hazy, smoky skies that frankly add stress and anxiety to my life. On my comment in the 2025 round: "I can not recall receiving a reply from my comments from the first round." I work for a non profit conservation center and for the last 8 years have led a group hiking program. I take community members out into the nearby mountains, recommended wilderness areas, and canyon country. But mostly I explore these areas on my own. Of Special interest to me - the West Elk Mts, The Ragged Mts; the San Juan Mts. To name a few. Most of these areas are currently either part of the Roadless Rule or designated wilderness. It would be a devastating sight for me if a new forest road is added to this area. We have thousands of Forest Roads already - there is no need to add any more. The country I am writing about includes the San Juan National Forest. I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule. I raise the following issues for the record and ask that the agency respond to each of them: Issue 1: Fragmentation is quantified and not applied I go out to watch wildlife and birds, and what I look for lives in unbroken habitat. The agency measured what fragmentation costs and then set the finding aside. The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. The number appears; no projection across the 40.1 million affected acres follows. I ask that the agency apply the cited fragmentation range to the 40.1 million acres of potentially affected environment. Issue 2: Elk survival, in the agency’s own citation I watch wildlife, and the animals I go looking for need country roads have not reached. The agency's own citation makes that point better than I can. The DEIS cites the finding that elk survival rates increased during a road closure and decreased when the gates were removed (Cole 1997), and that elk avoid roads and select unroaded habitat. No population-level effect on big game is projected anywhere in the document. I ask that the agency project the effects on big game populations and hunter opportunity. Issue 3: Carbon is stated and dropped The standing forests where I watch wildlife are doing quiet work the whole time, holding carbon. The agency states what these lands store and then drops the analysis. The DEIS cites the estimate that these inventoried roadless areas contain about 5 percent of the stored forest carbon in the coterminous United States, roughly 0.9 billion metric tons. The DEIS concludes these lands will continue to sequester and store carbon, with no analysis of harvest and roading. I ask that the agency quantify the change in carbon storage and sequestration under each alternative. I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule’s protections. Where this proposal rests on factual conclusions that differ from the agency’s own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record. Michael Burkley 40843 O Road Paonia, CO 81428