Comment Analysis · Docket FS-2025-0001

FS-2025-0001-338722

Opposes rescissionA0 noneSubstance 8/24Posted September 8, 2026 On Regulations.gov

In short: The comment documents that the proposed rescission of the Roadless Area Conservation Rule is driven by deregulatory goals rather than forest health, citing specific DEIS data on negative economic net present value, increased sedimentation, and biodiversity loss to support the No Action alternative.

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

Wildlife Habitat
- “Roads severely impact birds and wildlife”
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
- “Marten disappears when forest cover thins; wolverine avoid roads”
- “grizzly bear have suffered habitat loss and the extirpation or fragmentation of their populations”
Water Quality Quantity
- “Roads cause excessive damage to streams”
- “Skid roads, trails and log landings... are the main cause of soil erosion”
- “roads alter watershed hydrology, stream flows, water temperature regimes”
- “we must protect our water and it's sources”
Recreation Tourism Public Use
- “I am an avid hiker, fly fisher, bicyclist, nordic skier and birder”
- “I spend thousands of hours every year recreating on public lands”
- “lost recreation benefit by its own figures”
- “We particularly love the Chiricahua mountains”
Economic Impact Fiscal
- “The Forest Service cannot afford to maintain the existing roads”
- “Maximum projected timber revenue is $5.2 to 11.4 million a year”
- “net present value that runs to negative $92 million”
- “sacrificing our forests to make the rich richer”

What it names

National Forests: Bighorn National Forest Coronado National Forest Rio Grande National Forest San Juan National Forest
Roadless areas: Snowy Range

The comment

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

September 8, 2026 Comments to the proposal to rescind the Roadless Area Conservation Rule. Docket # FS-2025-0001. My name is Mark Seaton and I live in Mosca, Colorado at zip code 81146 I am a retired federal employee and worked for several land management agencies during my career. I am an avid hiker, fly fisher, bicyclist, nordic skier and birder. I spend thousands of hours every year recreating on public lands. I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I fully support Alternative 1, the No Action alternative. My wife and I love spending time in the National Forests near where we live. Including the Rio Grande National Forest, the San Juan National Forest, the Gunnison National Forest and the San Isabel National Forest. We also spend weeks camping in Wyoming. We particularly love the Medicine Bow National Forest and Snowy Range. We also love to camp in the Bighorn National Forest and backpack in the Wind River Range. In the winter months we like to travel to the Coronado National Forest in Arizona for hiking and cycling. We particularly love the Chiricahua mountains. The Forest Service cannot afford to maintain the existing roads. Road appropriations fell from $234 million in 2004 to $73 million in 2024, against a $6.9 billion deferred maintenance backlog. The supplemental funding is expiring. Maximum projected timber revenue is $5.2 to 11.4 million a year, against up to $6.1 million a year in lost recreation benefit by its own figures, and the agency’s own cost-benefit analysis states a net present value that runs to negative $92 million. Even DEIS states outright that road mileage, deferred maintenance and management costs are likely to increase. Roads cause excessive damage to streams. Skid roads, trails and log landings of timber operations are the main cause of soil erosion and can contribute up to 90 percent of the sediment generated by timber sale activity, and lists the consequences: lost spawning and rearing habitat, lost deep pools and cover, higher egg and juvenile mortality, blocked passage. The waters above these areas are clean today: less than 12 percent of the watersheds holding affected roadless areas have impaired streams. Roads severely impact birds and wildlife. The DEIS cites the findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. It is vital to avoid fragmentation of the roadless areas. The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent, that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter. Marten disappears when forest cover thins; wolverine avoid roads used by winter machines. On big animals, its own words: wide-ranging mammals like the grizzly bear “have suffered habitat loss and the extirpation or fragmentation of their populations.” In this time of changing climate in severe droughts we must protect our water and it’s sources. The DEIS: roads alter watershed hydrology, stream flows, water temperature regimes and stream channel morphology, and water yield and runoff in these areas are generally unaltered from natural conditions today. The affected areas overlap designated Wild and Scenic Rivers in the wild classification. The purpose of changing the roadless rules has nothing to do with forest health. The purpose and need is to reduce regulatory burden and return decision making to local officials, not forest health and not fire. Every conservation alternative was eliminated for failing that purpose: more acreage “would not be responsive to the deregulatory executive orders,” and one option was cut partly because analyzing roadless values is “an administrative and legal burden for the agency.” The agency even monetized what no roads in an area itself is worth to people who never visit: $5.3 to $11.5 million a year forgone, landing in the same range as the timber gain, which is why its own accounting cannot clear zero. And in its own words, “This proposed rescission does not mandate timber cutting or road construction”: nothing about management is promised, only the removal of the protection. This proposal is nothing more than a thinly veiled attempt to provide access to lands for oil, mining, timber and other extractive industries! It’s sacrificing our forests to make the rich richer nothing more. For the reasons listed above, fully or even partially rescinding the Roadless Rule under Alternatives 2 and 3 of the draft EIS would be a terrible mistake and would permanently damage our precious forest resources. I completely oppose the proposal to rescind or alter the Roadless Rule, and support Alternative 1, the No Action alternative. Thank you for allowing me to comment. Mark Seaton 719-588-7678