Comment Analysis · Docket FS-2025-0001

FS-2025-0001-404681

Opposes rescissionA2 moderateSubstance 11/24Owed an answerPosted September 15, 2026 On Regulations.gov

In short: The comment establishes that the DEIS fails to quantify the loss of elk and mule deer security habitat and sediment impacts to headwater watersheds, and documents that 76 percent of the acreage proposed for opening lacks wildland-urban interface justification, supporting a 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

A2 moderate: Hard to dismiss — it shows cause and effect.

Owed an answer on Analytical gap, Evidence, Alternative.

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
- “My calendar is built around it”
- “Winter is spent skiing”
- “Spring is runoff and rivers”
- “Summer is high country hiking, biking, and fishing”
Economic Impact Fiscal
- “economics in this proposal do not hold up”
- “return three orders of magnitude smaller than the liability”
- “lost recreation economic benefit”
- “net wash at best”
Water Quality Quantity
- “sediment and turbidity impacts to headwater watersheds”
- “forested headwaters are water infrastructure”
- “Road density is one of the strongest predictors of sediment delivery”
- “supply municipal and industrial water”
Wildlife Habitat
- “loss of elk and mule deer security habitat”
- “migration connectivity”
- “Fall is elk”

What it names

National Forests: Coconino National Forest Santa Fe National Forest Tonto National Forest

The comment

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

RIN 0596-AD66 / Docket FS-2025-0001 — Public comment opposing rescission of the 2001 Roadless Area Conservation Rule I am a mechanical engineer with 14 years of experience in power generation and water resources, and I live in Phoenix, Arizona. I am submitting this comment as a private citizen and public land owner. Roadless country is not something I visit occasionally. My calendar is built around it, and it is a primary reason I choose to live, work, and spend my money in Arizona, New Mexico, Colorado, Utah, California, Idaho, and Washington. Winter is spent skiing in the San Francisco Peaks on the Coconino National Forest (34.4220, -111.7338) and in the San Juan Mountains. Spring is runoff and rivers — the Colorado, the Little Colorado, the Salmon, the Dolores. Summer is high country hiking, biking, and fishing on the Fishlake (38.8799, -112.0654) and Manti-La Sal (39.0685, -111.3542) National Forests in Utah, the Inyo on the east side of the Sierra (37.6940, -118.3101), and the Cascades on the Okanogan-Wenatchee (47.3857, -121.0103). Fall is elk, in the Mazatzal country of the Tonto National Forest (34.0642, -111.7800), the White Mountains of the Apache-Sitgreaves, and the headwaters of the Santa Fe National Forest in northern New Mexico (36.1209, -106.2424). Every one of those trips runs on gas, food, lodging, licenses, tags, and gear bought in rural towns near those forests. The unroaded character of those places is the product I am paying for. Professionally, I manage capital projects, reliability, and deferred maintenance backlogs for a living, and I have done watersystem and water balance analysis in the arid Southwest. From that perspective the economics in this proposal do not hold up: • The proposal projects $5.2 to $11.4 million per year in Treasury and Forest Service revenue against an acknowledged $6.9 billion deferred maintenance backlog for roads and bridges. That is a return three orders of magnitude smaller than the liability the agency already cannot fund. In any asset management program I have worked in, adding new assets while a backlog of that size goes unaddressed is how systems fail. • The agency's own analysis estimates roughly $6.1 million per year in lost recreation economic benefit — which cancels out most or all of the projected timber revenue to the Treasury. The proposal is close to a net wash at best. • The proposal concedes that management opportunities would be "modest and localized," yet it exposes about 18.2 million acres (45.5 percent of the affected environment) to permanent road construction. The action is vastly broader than the need it claims to address. • If wildfire and community protection is the driving need, the analysis shows only 9.8 million acres — 24 percent — of inventoried roadless area overlaps the wildland-urban interface. That means 76 percent of the acreage being opened has no WUI justification at all. I would support an alternative narrowly scoped to fuels treatment in the WUI. Full rescission is not that alternative. • The DEIS does not adequately quantify what is actually being traded away: loss of elk and mule deer security habitat and migration connectivity, and sediment and turbidity impacts to headwater watersheds that supply municipal and industrial water. In the Southwest, forested headwaters are water infrastructure. Road density is one of the strongest predictors of sediment delivery, and that cost lands downstream on water users, not on the timber balance sheet. • Finally, the existing state-specific rules for Idaho and Colorado demonstrate that locally tailored roadless management is already achievable through petition and rulemaking. That undercuts the premise that a national rescission is necessary to escape a one-size-fits-all rule. I support the no action alternative. As a hunter, angler, skier, rafter, explorer and public land owner, I urge the U.S. Forest Service (USFS) to reject the proposed rescission of the 2001 Roadless Rule.