Comment Analysis · Docket FS-2025-0001

FS-2025-0001-279705

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

In short: The comment establishes that the agency's regulatory flexibility analysis is flawed for failing to assess the specific impact on local small entities in the Gila National Forest, and requests a site-specific environmental analysis and an alternative retaining the 2001 Roadless Area Conservation Rule for 28 named inventoried roadless areas.

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

Environmental Protection Biodiversity
- “protecting it from roads, clear-cutting, any development”
- “Any type of big cats, native birds, etc.”
- “pristine waters... fiercely protected for all human, wildlife and the trees themselves”
Water Quality Quantity
- “The water is so clean right now”
- “so many rely on these pristine waters”
- “fiercely protected for all human, wildlife and the trees themselves”
Recreation Tourism Public Use
- “We hike and take lots of photos and videos”
- “I hike and camp in these areas”
- “lost recreation benefit at a minimum of $6.1 million a year”
Legal Regulatory Framework
- “small-business certification contradicts the analysis”
- “withdraw the certification and assess the impact on the small entities”
- “analyze in the DEIS an alternative that retains the 2001 rule's protections”

What it names

National Forests: Gila National Forest
Roadless areas: Apache MountainAspen MountainBrushy MountainBrushy SpringsCanyon CreekDevils CreekDry CreekEagle PeakElk MountainFrisco BoxGila BoxHell HoleLower San FranciscoMeadow CreekMother HubbardPoverty CreekSawyers PeakStone CanyonT BarTaylor CreekThe HubWagon TongueWahoo Mountain

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 We hike and take lots of photos and videos at the Gila Cliff dwellings and spend time there in the dwellings. What I photograph out there: "The Gila Cliff dwellings, the forest, the Catwalk." What I go looking for out there: "Any type of big cats, native birds, etc." Our public land needs to be in the hands of the people who will take the best care of it by protecting it from roads, clear-cutting, any development. The water is so clean right now and since so many rely on these pristine waters, they must be fiercely protected for all human, wildlife and the trees themselves. We pay our money to maintain the existing roads and that isn't happening any longer. We do not need new roads that will also go unmaintained. We don't need new roads. We need the existing roads maintained properly. I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule, and specifically about these inventoried roadless areas: - Sawyers Peak (59,743 acres), Gila NF, New Mexico - Contiguous To Black & Aldo Leopold Wilderness (111,883 acres), Gila NF, New Mexico - Meadow Creek (34,167 acres), Gila NF, New Mexico - Contiguous To Gila Wilderness & Primitive Area (79,049 acres), Gila NF, New Mexico - T Bar (6,823 acres), Gila NF, New Mexico - Apache Mountain (17,506 acres), Gila NF, New Mexico - Eagle Peak (34,016 acres), Gila NF, New Mexico - Gila Box (23,759 acres), Gila NF, New Mexico - Dry Creek (26,719 acres), Gila NF, New Mexico - Wahoo Mountain (23,122 acres), Gila NF, New Mexico - Devils Creek (89,916 acres), Gila NF, New Mexico - Frisco Box (38,979 acres), Gila NF, New Mexico - Largo (12,731 acres), Gila NF, New Mexico - Brushy Springs (5,735 acres), Gila NF, New Mexico - Hell Hole (19,553 acres), Gila NF, New Mexico - Lower San Francisco (26,460 acres), Gila NF, New Mexico - Elk Mountain (6,550 acres), Gila NF, New Mexico - Wagon Tongue (11,411 acres), Gila NF, New Mexico - The Hub (7,498 acres), Gila NF, New Mexico - Aspen Mountain (23,784 acres), Gila NF, New Mexico - Stone Canyon (6,801 acres), Gila NF, New Mexico - Poverty Creek (8,770 acres), Gila NF, New Mexico - Brushy Mountain (7,199 acres), Gila NF, New Mexico - Canyon Creek (9,824 acres), Gila NF, New Mexico - Gila River Headwaters (4,286 acres), Gila NF, New Mexico - Mother Hubbard (5,895 acres), Gila NF, New Mexico - Nolan (13,051 acres), Gila NF, New Mexico - Taylor Creek (16,639 acres), Gila NF, New Mexico I ask that the agency disclose and analyze the site-specific environmental consequences of the proposed rescission for each of these areas, including the effects of the road construction and timber harvest it would newly allow. I raise the following issues for the record and ask that the agency respond to each of them: Issue 1: The small-business certification contradicts the analysis beside it I hike and camp in these areas, and the small outfitters and guides who work this same country help people like me get out there. They deserve a real assessment. 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. The supporting regulatory flexibility analysis reaches its no-impact conclusion by spreading the $9 million annual expenditure loss across every small firm in the sector nationally, rather than assessing the outfitters and guides actually holding permits in the affected areas, and concedes some firms may lose these receipts. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. 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 for the areas named above. 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. Sincerely, Cathy Winkley Cedar Park, TX Relatives in Silver City, NM. Vacation there and support the economy often!