Comment Analysis · Docket FS-2025-0001

FS-2025-0001-279383

Opposes rescissionA2 moderateSubstance 14/24Owed an answerPosted August 28, 2026 On Regulations.gov

In short: The comment establishes that the agency's rescission proposal is internally inconsistent with its own DEIS data regarding wildfire density and economic net benefits, fails to properly assess impacts on small businesses in affected areas, and neglects to weigh reliance interests as required by administrative law.

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

A2 moderate: Hard to dismiss — it shows cause and effect.

Owed an answer on Analytical gap, 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.
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.

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.
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

Forest Management Wildfire
- “Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires”
- “A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands”
- “DEIS Table 21 reports far higher fire density on roaded land than inside the affected roadless areas”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year”
- “road system the rescission would expand already carries a $6.9 billion maintenance backlog”
Legal Regulatory Framework
- “a change of course requires identifying and weighing the reliance interests the prior rule created”
- “The agency must identify and weigh the reliance interests described in the record before it acts”
- “The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected”
Recreation Tourism Public Use
- “The Colorado Trail winds through country I hike and photograph”
- “recreation losses of at least $6.1 million a year”
- “My own use of Rocky Mountain National Park, the Colorado Trail, and the Badlands and Wind Cave landscapes is built on a reasonable expectation that the protections in place stay in place”

What it names

Roadless areas: Rocky Mountain

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Colorado Trail winds through country I hike and photograph, and the Wyoming and Colorado Rockies are where I camp and spend time looking for what is still wild. The rescission of the 2001 Roadless Area Conservation Rule, proposed under Docket FS-2025-0001, works against the principle I hold most plainly: public land should be managed for the people, now and permanently into the future. What follows are specific concerns the agency has not resolved. The agency's own findings on fire contradict a central justification offered for this rescission. The record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal nonetheless advances road construction in inventoried roadless areas partly on fuels management grounds. DEIS Table 21 reports far higher fire density on roaded land than inside the affected roadless areas, which makes that justification harder to follow, not easier. I ask the agency to explain why the proposal departs from these prior findings and to reconcile the rescission with that ignition data in its own DEIS. The economic case is similarly unsettled by the agency's own numbers. The record acknowledges that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Alongside that, the agency's Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year, with a net present value spanning -$92 million to +$199 million. The road system the rescission would expand already carries a $6.9 billion maintenance backlog. The agency should explain how an action whose own analysis cannot establish a net benefit justifies adding to that liability. The agency's treatment of small businesses does not survive contact with the rest of the record. The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. That certification rests on spreading the $9 million annual expenditure loss across every small firm in the sector nationally, rather than on any assessment of the outfitters, guides and permit holders actually operating in the affected areas. The agency concedes some firms may lose these receipts. The certification should be withdrawn and replaced with an analysis of the small entities who hold permits and run operations in the roadless areas actually at issue, not a national average. The proposal solicits “any reliance interests in the current rule that could be affected by this proposal” (91 FR 53830-31), and the Cost Benefit Analysis weighs none. Under the administrative law principles the agency is bound by, a change of course requires identifying and weighing the reliance interests the prior rule created. The comments the agency receives, including this one, describe exactly those interests. Across the Rocky Mountain region, which includes Colorado, 325 municipal water intakes sit in watersheds containing affected roadless areas, according to DEIS Table 35. My own use of Rocky Mountain National Park, the Colorado Trail, and the Badlands and Wind Cave landscapes is built on a reasonable expectation that the protections in place stay in place. The agency must identify and weigh the reliance interests described in the record before it acts. Colorado's roadless areas are governed by the 2012 Colorado Roadless Rule, which the current proposal retains. The agency should state plainly on the record what, if anything, changes in the management of those areas under the rescission as proposed, so that commenters whose connection is primarily to Colorado can assess the actual effect on the land they use. Sincerely, Bharat Ratra Manhattan, KS 66502