Comment Analysis · Docket FS-2025-0001

FS-2025-0001-344273

Opposes rescissionA2 moderateSubstance 15/24Owed an answerPosted September 12, 2026 On Regulations.gov

In short: The comment documents that the agency's analysis fails to quantify the interaction between increased human-caused ignitions from road access and claimed wildfire hazard reduction, does not apply cited habitat fragmentation statistics to the 40.1 million acres of affected environment, and does not adequately assess the economic impact on specific small entities or clarify the legal status of Colorado's roadless areas post-rescission.

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

Recreation Tourism Public Use
- “Continental Divide Trail through southwest Colorado is where I backpack”
- “want that country preserved as natural and wild”
- “lost recreation benefit at a minimum of $6.1 million a year”
- “Backpackers, recreationists and communities across the country have ordered their choices around the protections”
Governance Policy Process
- “certification that the action will have no significant impact on small entities”
- “averaging exercise that obscures real harm”
- “obligated to identify and account for the reliance its prior policy created”
- “ask the agency to withdraw the certification and conduct a genuine evaluation”
Forest Management Wildfire
- “Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas”
- “human-caused ignitions increase in abundance with proximity to roads”
- “road access could increase the number and frequency of wildfires”
- “calculate the expected increase in human-caused ignitions that would follow from new road access”
Environmental Protection Biodiversity
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
- “applied to 40.1 million acres, would mean for the wildlife and watersheds within them”
- “honest accounting of what that fragmentation range... would mean for the wildlife”
- “preserve... natural and wild”

What it names

National Forests: San Juan National Forest

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Continental Divide Trail through southwest Colorado is where I backpack, and I want that country preserved as natural and wild. The Hermosa area within the San Juan National Forest, part of the 4,407,277 acres held in Colorado's 326 inventoried roadless areas, represents exactly what the 2001 Roadless Area Conservation Rule was built to protect. I oppose the proposed rescission of that rule and ask the agency to address the following points in its record. The proposed rule carries a certification that the action will have no significant impact on small entities. That certification cannot be squared with what the agency's own analysis shows. "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 regulatory flexibility analysis reaches its no-impact conclusion by distributing a $9 million annual expenditure loss across every small firm in the sector at the national level, not by examining the outfitters and guides who actually hold permits in the specific roadless areas at issue. The analysis itself concedes that some firms may lose those receipts. That is not an assessment of impact on small entities; it is an averaging exercise that obscures real harm. I ask that the agency withdraw the certification and conduct a genuine evaluation of the small businesses actually operating in the potentially affected roadless areas. Backpackers, recreationists and communities across the country have ordered their choices around the protections the 2001 rule put in place. The agency invites exactly that kind of testimony: The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. When an agency changes course, it is obligated to identify and account for the reliance its prior policy created. This comment is one such interest. Having solicited reliance interests from the public, the agency must then weigh them. I ask that the record show how the agency evaluated the reliance interests described in the comments it received, including this one. The agency's own fire data presents a serious problem for the proposal's justification. "Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads." The effects analysis itself acknowledges that road access could increase the number and frequency of wildfires. Yet the proposal is in part justified on wildfire hazard reduction grounds. The agency cannot simultaneously hold that roads increase human-caused ignitions and that opening roadless areas to road construction will reduce fire risk without quantifying how those two conclusions interact. The agency must calculate the expected increase in human-caused ignitions that would follow from new road access and set that figure alongside the claimed reduction in wildfire hazard before this record is closed. The fragmentation finding embedded in the DEIS raises a concern the analysis never resolves. "The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent." That range appears in the document and then stops there. No projection of what that reduction means across the 40.1 million acres of potentially affected environment follows. A number cited but never applied to the landscape it describes is not analysis; it is decoration. Hermosa and every other inventoried roadless area that could be affected deserve an honest accounting of what that fragmentation range, applied to 40.1 million acres, would mean for the wildlife and watersheds within them. The agency should apply that cited range to the full potentially affected acreage and show its work. Colorado's roadless areas, including Hermosa, are governed by the 2012 Colorado Roadless Rule, which the current proposal leaves in place. But the downstream effects of a national rescission, including any shift in administrative posture toward roadless protection generally, remain unaddressed for Colorado specifically. I ask the agency to clarify on the record what, if anything, changes for Colorado roadless areas in management practice or legal standing if the 2001 rule is rescinded, so that Colorado commenters can evaluate the real stakes of this proposal for their landscapes. Sincerely, [Loyde Carpenter ] [Palm Bay, FL]