Comment Analysis · Docket FS-2025-0001

FS-2025-0001-315888

Opposes rescissionA0 noneSubstance 7/24Posted September 4, 2026 On Regulations.gov

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

In short: The comment documents the commenter's personal use of national forests in New Mexico and Colorado and argues that the agency failed to demonstrate that nationwide rescission of the 2001 Roadless Area Conservation Rule is necessary when targeted, place-specific alternatives exist.

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

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 western watersheds should be a primary reason to retain the Roadless Rule”
- “Roadless forests capture snow and rainfall, filter water, stabilize soils, and limit erosion and sedimentation”
- “Road construction and associated logging can increase erosion and sedimentation and fragment intact watersheds”
Forest Management Wildfire
- “I agree that reducing wildfire risk and restoring forest health are urgent priorities”
- “Roads can also increase human access and opportunities for human-caused ignitions”
- “Limited wildfire-management resources should be directed to treatments demonstrated to reduce risks to communities”
Economic Impact Fiscal
- “The Forest Service already manages more than 371,000 miles of roads and faces nearly $5 billion in deferred transportation maintenance”
- “Adding roads to a system the agency already struggles to maintain is fiscally irresponsible”
- “New roads create continuing costs for drainage, erosion control, repairs, and eventual decommissioning”
Recreation Tourism Public Use
- “I spend considerable time hiking, skiing, camping, and exploring the Coronado and Coconino National Forests”
- “The Coronado, Coconino, and White River National Forests are places I return to year after year”

The comment

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

I strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and urge the Forest Service to retain the rule. National forests are an important part of my life. I spend time hiking, skiing, camping, biking, birding and exploring primarily in New Mexico and Colorado National Forests. My opposition to rescission is based particularly on four concerns: watersheds, wildfire, costs, and the availability of targeted alternatives. Watersheds. Protecting western watersheds should be a primary reason to retain the Roadless Rule. Roadless forests capture snow and rainfall, filter water, stabilize soils, and limit erosion and sedimentation. These functions are especially important in the arid West. Road construction and associated logging can increase erosion and sedimentation and fragment intact watersheds. At a time of persistent drought, higher temperatures, and increasing demands on limited western water supplies, we should be protecting these natural systems, not weakening them. The Forest Service should fully account for the value of the watershed services provided by roadless areas and the long-term costs of degrading them. Wildfire. reducing wildfire risk and restoring forest health are urgent priorities, but the Forest Service should demonstrate that rescinding the Roadless Rule would actually accomplish those goals. The existing rule already allows road construction in some circumstances to address fire risk and allows thinning of young trees to reduce hazardous fuels. Roads can also increase human access and opportunities for human-caused ignitions; research cited by the Grand Canyon Trust finds fires are substantially more likely to start in areas with roads. Limited wildfire-management resources should be directed to treatments demonstrated to reduce risks to communities, homes, and infrastructure. The Forest Service should show that opening millions of roadless acres to additional roads and logging would reduce wildfire risk more effectively than strategically located treatments, particularly near the wildland-urban interface. Costs. The Forest Service already manages more than 371,000 miles of roads and faces nearly $5 billion in deferred transportation maintenance. Adding roads to a system the agency already struggles to maintain is fiscally irresponsible. New roads create continuing costs for drainage, erosion control, repairs, and eventual decommissioning. The Forest Service should account for these full life-cycle costs and explain why facilitating additional road construction makes sense when existing roads already have such a substantial maintenance backlog. Targeted alternatives. The Forest Service has not demonstrated that management problems in particular locations require rescinding protections across roughly 45 million acres nationwide. If specific roadless areas present circumstances in which existing exceptions prevent necessary wildfire mitigation, restoration, or other essential management, those circumstances should be identified and addressed specifically. If the problem is place-specific, the solution should be place-specific. The Forest Service should seriously evaluate retaining the Roadless Rule while modifying or expanding narrowly defined exceptions where a legitimate management need can be demonstrated. It should explain why targeted changes are inadequate before choosing nationwide rescission. The Roadless Rule has protected these lands for 25 years while allowing exceptions for legitimate management needs. Protecting intact watersheds, directing wildfire resources where they will be most effective, avoiding unnecessary infrastructure costs, and choosing targeted solutions over nationwide rescission are sound principles of public-land management. Please retain the 2001 Roadless Area Conservation Rule.