Comment Analysis · Docket FS-2025-0001

FS-2025-0001-356837

Opposes rescissionA2 moderateSubstance 14/24Owed an answerPosted September 12, 2026 On Regulations.gov

In short: The comment places on the record specific deficiencies in the agency's analysis regarding wildfire ignition data, economic net benefits, and small entity impacts, while documenting the commenter's reliance interests in the White River National Forest roadless areas and the lack of public meetings for the 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
- “fairy slipper orchids come up in the early summer”
- “tracking paintbrushes and elephantella”
- “most visited national forest in Colorado”
- “recreation losses of at least $6.1 million a year”
Water Quality Quantity
- “headwaters of the Colorado River”
- “supplies water to 40 million people”
- “roadless landscape represents water”
Governance Policy Process
- “held exactly none to undo it”
- “huge changes to public land do not happen without public input”
- “regulatory flexibility analysis certifies no significant impact on small entities”
- “agency must identify and weigh the reliance interests”
Forest Management Wildfire
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “DEIS Table 21 confirms far higher fire density on roaded land”
- “agency's stated justification for rescission includes fuels and fire management”

What it names

National Forests: White River National Forest

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The fairy slipper orchids come up in the early summer in the White River National Forest. By midsummer my family is tracking paintbrushes and elephantella, and by late summer we are working to find all six local species of gentian on a single hike. I hike on and off trail there because the roadless landscape represents water, wildlife, connection with nature, and generational wisdom. I am writing in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001. The White River holds 90 inventoried roadless areas totaling 639,604 acres. It is the headwaters of the Colorado River, which supplies water to 40 million people in seven states and Mexico, and it is the most visited national forest in Colorado. Colorado roadless areas are currently governed by the 2012 Colorado Roadless Rule, which the proposal states it would retain. What the agency has not explained is what, if anything, changes in their management as a consequence of this rescission. I ask the agency to answer that question directly and specifically on the record. On wildfire, the agency's stated justification for rescission includes fuels and fire management, but the agency's own prior findings cut the other way. The record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." DEIS Table 21 confirms far higher fire density on roaded land than inside the affected roadless areas. The proposal does not reconcile itself with those findings. I ask that the agency explain why it is departing from them and how it accounts for the ignition data in its own analysis. On economics, the scale of what is at stake is modest by the agency's own numbers: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Yet the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year, with a net present value spanning -$92 million to +$199 million. The Forest Service is already carrying a $6.9 billion road maintenance backlog. The agency must explain on the record how expanding a road system burdened by that backlog is justified when its own analysis cannot establish a net benefit. The regulatory flexibility analysis certifies no significant impact on small entities, but the DEIS identifies outfitters, guides, and tour operators as affected, and the Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. The certification reaches its conclusion by spreading losses across every small firm in the sector nationally rather than examining the outfitters and guides who actually hold permits in the affected areas, and it concedes that some of those firms may lose those receipts. The certification should be withdrawn and the analysis should assess the businesses actually operating in the potentially affected roadless areas. 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. My family has built our seasonal routine around the wildflowers of these roadless areas. The gentians, the orchids, the paintbrushes exist in the condition they do because roads have not come in behind them. That is a reliance interest. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. My children deserve to inherit roadless places and a democracy in which huge changes to public land do not happen without public input. The Forest Service held more than 600 public meetings and took 1.6 million comments to write the Roadless Rule, but has held exactly none to undo it. That is wrong, and the agency should say plainly how it answers for it. Sincerely, Denali Barron Aspen, Colorado