Comment Analysis · Docket FS-2025-0001

FS-2025-0001-365655

Opposes rescissionA3 weakSubstance 12/24Owed an answerPosted September 12, 2026 On Regulations.gov

In short: The comment establishes that the commenter is a New Mexico resident with personal reliance on specific National Forests for subsistence and recreation, and cites 2026 scientific data demonstrating that road proximity increases wildfire ignition density to refute the agency's justification for rescinding the Roadless Rule.

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

A3 weak: Substantive, but easier to set aside.

Owed an answer on 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.
  • 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.
  • 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.
  • 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

  • Environmental Protection Biodiversity
    • “keep New Mexico forest areas free of roads, logging and extractive industries”
    • “protecting roadless forests”
    • “find them criss-crossed with roads”
  • Recreation Tourism Public Use
    • “hike or snowshoe in the nearby Cibola National Forest”
    • “most important memories of my mother... snowshoeing together”
    • “escape the city”
  • Forest Management Wildfire
    • “increase forest fires”
    • “highest wildfire-ignition density was in lands within 50 m of roads”
    • “don't try to claim that the repeal of the Roadless Rule is to prevent or reduce wildfires”
  • Governance Policy Process
    • “established after 600 public meetings and 1.6 million comments”
    • “broadest public engagement efforts ever”
    • “served the voting public well for twenty-five years”

What it names

National Forests
Carson National ForestCibola National ForestLincoln National ForestSanta Fe National Forest
Works cited
10.1186/s42408-026-00450-2

The comment

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

I am a citizen of New Mexico and I am writing to strongly oppose rescission of the Roadless Rule. The Roadless Rule is twenty-five years old and was established after 600 public meetings and 1.6 million comments by the public. The establishment of the Roadless Rule followed one of the broadest public engagement efforts ever by the US Forest Service, and that showed once and for all that there is outstanding positive support for protecting roadless forests. In New Mexico alone, there are 1.6 million acres of Inventoried Roadless Areas. It is important to me personally to keep New Mexico forest areas free of roads, logging and extractive industries. First of all, my family is fed by the venison, duck, elk and fish that my brother, a licensed hunter and fisherman, hunts and catches on roadless areas including in the Pecos Wilderness, the Lincoln National Forest and the Carson National Forest. Secondly, although I live in Albuquerque which is a metropolitan area of about a million people, for my mental health, I can quickly escape the city and hike or snowshoe in the nearby Cibola National Forest. I also hike and snowshoe in the Santa Fe National Forest; in fact, some of my most important memories of my mother, who died in 2025, are of us snowshoeing together in National Forest lands. I would be devastated if I were to return to those places and find them criss-crossed with roads. Thirdly, as a taxpayer, I am completely opposed to using my tax dollars to build new roads which then are more likely to increase forest fires—which also need to be fought using my tax dollars. A January 2026 scholarly article in journal Fire Ecology [full citation below*] concluded that: “The highest wildfire-ignition density was in lands within 50 m of roads (7.99 fires/1000 ha), and the second highest wildfire-ignition density was in other national forest lands outside of the 50-m road buffers but not in wilderness or roadless areas (3.50 fires/1000 ha).” In plain English that means that fires are most likely to start within 50 meters of roads, not in roadless areas. So, please, don’t try to claim that the repeal of the Roadless Rule is to prevent or reduce wildfires—we, the public, know better! In summary, keep the Roadless Rule as is--it has served the voting public well for twenty-five years and there are no valid reasons to change it. * Aplet, G.H., Hartger, P. & Dietz, M.S. Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. fire ecol 22, 8 (2026). https://doi.org/10.1186/s42408-026-00450-2

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