Comment Analysis · Docket FS-2025-0001

FS-2025-0001-357050

Opposes rescissionA2 moderateSubstance 13/24Owed an answerPosted September 12, 2026 On Regulations.gov

In short: The Gunnison and Colorado watersheds are where the commenter spends significant time, and they oppose the rescission of the 2001 Roadless Area Conservation Rule due to its impact on river health and water quality.

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
- “seen firsthand what roads and expanded human access do to a river's health”
- “pristine headwaters of the Gunnison River”
- “headwaters of the Colorado River, which supplies water to 40 million people”
- “water I drink from the Gunnison and Colorado watersheds”
Recreation Tourism Public Use
- “I hike and backpack in the Gunnison National Forest”
- “I paddle those rivers and their tributaries”
- “lost recreation benefit at a minimum of $6.1 million a year”
- “My paddling, my hiking”
Forest Management Wildfire
- “Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “reconcile the rescission with the fire density data in DEIS Table 21”
- “far higher fire incidence on roaded land than inside the affected roadless areas”
Wildlife Habitat
- “hike and paddle in the elk habitat of the Gunnison country”
- “elk survival is known to rise during road closures and fall when gates reopen”
- “elk select unroaded land for cover and forage”
- “Roads are not a neutral instrument in these landscapes”

What it names

National Forests: White River National Forest
Roadless areas: Beaver Creek

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific place

The Gunnison and Colorado watersheds are where I spend the time that matters most to me. I hike and backpack in the Gunnison National Forest, the Grand Mesa National Forest, the White River National Forest, the West Elk Wilderness, the Raggeds Wilderness, the Mount Sneffels Wilderness, and other wild places across Colorado. I paddle those rivers and their tributaries, and I have seen firsthand what roads and expanded human access do to a river's health. I have also stood at the pristine headwaters of the Gunnison River, in areas protected by the Roadless Rule, and understood clearly that those waters would be worse off if these protections were lifted. That is why I oppose the rescission of the 2001 Roadless Area Conservation Rule under Docket FS-2025-0001. The inventoried roadless areas I care about most directly include Roubideau (21,575 acres), Kelso Point (34,353 acres), Cimarron (15,638 acres), Tabeguache (11,504 acres), Beaver Creek (1,877 acres), and Badly Peak (1,948 acres), all within the Grand Mesa-Uncompahgre-Gunnison National Forest. The White River National Forest, where I also spend time, holds 90 inventoried roadless areas totaling 639,604 acres and contains the headwaters of the Colorado River, which supplies water to 40 million people in seven states and Mexico. I understand that Colorado roadless areas are currently governed by the 2012 Colorado Roadless Rule, which this proposal retains. I ask the agency to explain specifically what changes, if anything, in the management of Colorado roadless areas as a result of this rescission, and to answer that question on the record. The proposal uses wildfire and fuels management as partial justification for opening roadless areas to road construction. The agency's own record says otherwise. Its prior findings state: "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." I hike and paddle in the elk habitat of the Gunnison country, where elk survival is known to rise during road closures and fall when gates reopen, because elk select unroaded land for cover and forage. Roads are not a neutral instrument in these landscapes. I ask that the agency explain how the proposal departs from its own prior ignition findings and reconcile the rescission with the fire density data in DEIS Table 21, which shows far higher fire incidence on roaded land than inside the affected roadless areas. The small-business certification accompanying this proposal is contradicted by the analysis sitting beside it. "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." That certification was reached by spreading an annual expenditure loss across every small firm in the sector nationally, not by assessing the outfitters and guides who actually hold permits in the affected areas. The agency concedes some firms may lose those receipts. The agency must withdraw the certification and conduct an honest assessment of the small entities actually operating under permits in these areas, not the national average firm. Finally, the proposal itself 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. This comment is one such interest. My paddling, my hiking, and the water I drink from the Gunnison and Colorado watersheds have all been shaped by the expectation that these protections would hold. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. Sincerely, Bekah Scalero Paonia, CO