Comment Analysis · Docket FS-2025-0001

FS-2025-0001-326950

Opposes rescissionA2 moderateSubstance 11/24Owed an answerPosted September 7, 2026 On Regulations.gov

In short: The comment documents that the DEIS lacks quantitative water quality modeling and a cumulative effects analysis integrating the One Big Beautiful Bill Act's statutory timber harvest mandate with Roadless Area Conservation Rule projections, and requests that the agency address these analytical gaps before proceeding.

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

Water Quality Quantity
- “New Mexico's water is a precious resource that must be protected at all costs”
- “opening those lands to road construction and timber harvest introduces sediment, pathogens, and runoff”
- “no quantitative modeling of sediment loads, pathogen risk, or the treatment cost increases”
Recreation Tourism Public Use
- “My family wants to continue hiking the trails of Carson National Forest and Santa Fe National Forest”
- “The trails of Carson National Forest and Santa Fe National Forest represent something my family values”
- “puts that future at serious risk”
Governance Policy Process
- “The agency must explain, on the record, how it can justify rescinding nationwide protections while leaving that analytical gap unfilled”
- “The agency should prepare and release a cumulative effects analysis combining that statutory obligation with IRA-specific projections”
- “Returning to that approach... is not a course of responsible management”
Resource Development Extraction
- “I also do not want my taxes used to open up these protected lands to mining and logging operations”
- “projected increases in sawtimber harvest under alternatives 2 and 3”
- “sell a quantity of timber on National Forest System land that is at least 250 million board feet greater”

What it names

National Forests: Carson National Forest Santa Fe National Forest

The comment

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

My family wants to continue hiking the trails of Carson National Forest and Santa Fe National Forest, and this proposed rescission of the 2001 Roadless Area Conservation Rule puts that future at serious risk. I oppose the proposal and ask the agency to address the specific concerns below before moving forward. New Mexico's water is a precious resource that must be protected at all costs. Roadless areas across the national forests feed the watersheds that communities depend on, and opening those lands to road construction and timber harvest introduces sediment, pathogens, and runoff that no set of management practices can fully prevent. The scale of exposure here is not abstract. As documented in Table 35 of the DEIS, "there are more than 7,000 municipal water intakes within watersheds containing potentially affected inventoried roadless areas." Despite that documented exposure, the water quality analysis in the DEIS is entirely qualitative and programmatic. There is no quantitative modeling of sediment loads, pathogen risk, or the treatment cost increases that road construction and timber harvest could generate. The document acknowledges that Best Management Practices reduce but do not eliminate impacts, which is not an adequate substitute for watershed-specific analysis. The agency must explain, on the record, how it can justify rescinding nationwide protections while leaving that analytical gap unfilled. I also do not want my taxes used to open up these protected lands to mining and logging operations that will hurt the ecosystem for decades to come. The DEIS frames projected increases in sawtimber harvest under alternatives 2 and 3 as a national benefit, but it does not honestly account for what that harvest pressure means when layered onto existing statutory obligations. As noted at Table 4 of the DEIS, the One Big Beautiful Bill Act "Directs the Forest Service to annually, beginning in FY2026 and through FY2034, sell a quantity of timber on National Forest System land that is at least 250 million board feet greater than the quantity that was sold in the previous fiscal year." That mandate applies to National Forest System lands regardless of this rulemaking. The DEIS lists that Act as a reasonably foreseeable action but never integrates it with IRA-specific harvest projections into a genuine cumulative effects analysis. The operability estimates the agency relies on to predict IRA harvest levels were not developed against a backdrop of a decade-long, escalating statutory volume mandate. The agency should prepare and release a cumulative effects analysis combining that statutory obligation with IRA-specific projections across all affected resource areas before this rule is finalized. The trails of Carson National Forest and Santa Fe National Forest represent something my family values and wants to pass on. The protections established in 2001 have kept those landscapes intact precisely because site-by-site, forest-by-forest decisionmaking lacked consistent standards. Returning to that approach, against a backdrop of escalating harvest mandates and unanalyzed water quality risks, is not a course of responsible management. The agency should answer each of the points raised above before it proceeds further with this proposal.