Comment Analysis · Docket FS-2025-0001

FS-2025-0001-285408

Opposes rescissionA0 noneSubstance 7/24Posted August 29, 2026 On Regulations.gov

In short: The comment places on the record specific opposition to the rescission of the 2001 Roadless Rule, citing ecological fragmentation data and identifying the Comanche Peak Adjacent Area in the Arapaho & Roosevelt NFs as a location where road construction would cause habitat fragmentation and water quality degradation.

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

  • Environmental Protection Biodiversity
    • “Ecosystem and Biodiversity Protection”
    • “unfragmented habitat for over 1,600 threatened, endangered, and sensitive species”
    • “fragment migration corridors, introduces invasive weed species”
  • Water Quality Quantity
    • “Watershed Security”
    • “safeguard the source waters for 354 municipal watersheds”
    • “increases soil erosion, sedimentation, and runoff pollution”
  • Forest Management Wildfire
    • “Removing roadless protections under the guise of wildfire mitigation is counterproductive”
    • “road construction increases human-caused fire starts”
    • “strategic, community-adjacent hazardous fuels reduction”
  • Recreation Tourism Public Use
    • “Intact roadless areas support thriving outdoor recreation economies”
    • “risks long-term economic harm to local communities reliant on sustainable recreation and tourism”
    • “clean air, soundscapes”

What it names

Roadless areas
Comanche Peak Adjacent Area
Works cited
10.1146/annurev.ecolsys.29.1.207

The comment

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

Dear Secretary and Chief: As someone who has walked the same public land for years, I notice what changes. Roads change everything. I am writing to express my strong opposition to the Department of Agriculture’s proposal to rescind the 2001 Roadless Area Conservation Rule. For 25 years, the Roadless Rule has served as a foundational conservation policy, safeguarding 58.5 million acres of undeveloped national forest lands A relationship of this kind constitutes a cognizable public interest, and one the Department is statutorily bound to consider. Regarding the Comanche Peak Adjacent Area in the Arapaho & Roosevelt NFs, Colorado: New road construction, reconstruction, and associated development fragment habitat, introduce disturbance, and eliminate roadless character. A large share of the U.S. is already road-affected. An estimated 15 to 20 percent of the contiguous United States is ecologically affected by roads, accounting for edge effects, runoff patterns, and downstream disturbance — not just the area of road surface itself. Roughly 80 percent of Earth's terrestrial surface remains roadless, but most of that area is fragmented into patches smaller than 1 square kilometer (Forman & Alexander 1998; Ibisch et al. 2016). — Richard T. T. Forman | Lauren E. Alexander, 1998 · Annual Review of Ecology, Evolution, and Systematics (https://doi.org/10.1146/annurev.ecolsys.29.1.207) Rescinding the Roadless Rule would open the Comanche Peak Adjacent Area, Arapaho & Roosevelt NFs to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. I urge the Forest Service to select Alternative 1 (No Action) in the Draft Environmental Impact Statement to maintain full protections for these undeveloped areas based on the following substantive points: •Ecosystem and Biodiversity Protection: Roadless areas encompass vital, unfragmented habitat for over 1,600 threatened, endangered, and sensitive species. Constructing roads through these pristine forest fragments migration corridors, introduces invasive weed species, and increases poaching risks. •Watershed Security: Roadless national forest lands safeguard the source waters for 354 municipal watersheds, providing clean, reliable drinking water to millions of Americans. New road construction significantly increases soil erosion, sedimentation, and runoff pollution in these municipal water supplies. •Wildfire Risk and Forest Management: Removing roadless protections under the guise of wildfire mitigation is counterproductive. Studies show that road construction increases human-caused fire starts. The agency should focus its resources on strategic, community-adjacent hazardous fuels reduction rather than opening remote backcountry areas to commercial development. •Economic Value: Intact roadless areas support thriving outdoor recreation economies, clean air, soundscapes, and carbon storage. The DEIS acknowledges that eliminating these protections risks long-term economic harm to local communities reliant on sustainable recreation and tourism. I request that the Forest Service uphold the 2001 Roadless Rule to preserve these intact landscapes for current and future generations. I ask that these comments be read alongside the many others opposing rescission and that the Department act consistent with the weight of that record. Yours sincerely, Dianne Dallin CommentID: RLC-20260829-V4D9KS

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