Comment Analysis · Docket FS-2025-0001

FS-2025-0001-418107

Opposes rescissionA1 strongSubstance 14/24Owed an answerPosted September 16, 2026 On Regulations.gov

In short: The comment documents specific deficiencies in the agency's analysis regarding wildfire ignition data, economic cost-benefit projections, and the rejection of protective alternatives, while citing specific geographic areas and legal precedents to argue that the rescission of the Roadless Area Conservation Rule is inconsistent with the agency's own record and statutory authority.

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

A1 strong: Must be answered — it names the law.

Owed an answer on Analytical gap, Legal.

Standard dismissals it defeats

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.
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.
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.

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.
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.

Topics

Recreation Tourism Public Use
- “I fish, camp, and hike in the mountains of Colorado”
- “quiet solitude”
- “recreation losses of at least $6.1 million a year”
- “My kids should not inherit fewer of these places than I did”
Wildlife Habitat
- “wildlife like elk, bighorn sheep, and mountain goats”
- “elk avoid roaded areas and that their survival rates rose during a road closure”
- “bird richness declines with road presence”
- “protections for big game habitat, fisheries, and wildlife connectivity”
Forest Management Wildfire
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires”
- “reconcile the rescission with the ignition data in its own DEIS”
- “justifies rescission partly on wildfire and fuels management grounds”
Legal Regulatory Framework
- “The Tenth Circuit held... REVERSE the district court's order”
- “rule fell within authority granted under the Organic Act and MUSYA”
- “Ninth Circuit found it wanting”
- “state-by-state rulemaking can replace a national rule”

What it names

National Forests: Allegheny National Forest Huron-Manistee National Forest
Roadless areas: Allegheny FrontBear SwampGreen Mountain
Law cited: 28 U.S.C. Section 1291

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I fish, camp, and hike in the mountains of Colorado. Rivers, lakes, trails, the views, the quiet solitude, and wildlife like elk, bighorn sheep, and mountain goats are what I go there for. Logging and road construction in those areas would destroy it. I want my kids to be able to enjoy these areas intact and protected , and the Forest Service's proposal to rescind the 2001 Roadless Area Conservation Rule does the opposite. The agency's own record is the most damaging witness against this proposal. The agency's prior analysis found that "a human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands," and that "building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires." The proposal nonetheless justifies rescission partly on wildfire and fuels management grounds. The agency must explain the basis for departing from its own findings on fire occurrence, and reconcile the rescission with the ignition data in its own DEIS, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic rationale is no stronger. The record states that "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." Against that baseline, the agency's own cost-benefit analysis projects timber revenue of $5.2 to $11.4 million a year to the Forest Service against recreation losses of at least $6.1 million a year, and a net present value spanning negative $92 million to positive $199 million. The agency must explain how an action whose own analysis cannot establish a net benefit justifies expanding a road network already carrying a $6.9 billion maintenance backlog. The agency also argues that state-by-state rulemaking can replace a national rule. The record shows the agency once "discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." That experiment was reviewed by the courts, and the Ninth Circuit found it wanting. The agency should address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and explain how this proposal avoids the same deficiencies identified when the national rule was last dismantled piece by piece. On authority: a court has already reviewed whether the 2001 rule exceeded statutory power. The Tenth Circuit held, "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The agency should address that holding, explain how it squares any contrary position with the Tenth Circuit's conclusion that the rule fell within authority granted under the Organic Act and MUSYA, and did not create de facto wilderness. The areas at stake to me are not abstractions. Mt. Evans Adjacent Area in the Arapaho-Roosevelt National Forest defines Denver's skyline and the character of the land surrounding it. Indian Peaks Adjacent Area, also in the Arapaho-Roosevelt, looks straight out of a painting, especially at sunset. Green Mountain in the Pike-San Isabel National Forest deserves a visit before anyone considers letting it be logged. The agency's own record confirms that elk avoid roaded areas and that their survival rates rose during a road closure and fell when the gates came back off. It also confirms that bird richness declines with road presence, and that road noise cut bird abundance by over a quarter in a roadless area, with 31 percent of species avoiding the noise entirely. The elk, bighorn sheep, mountain goats, and birds I look for in these places depend on keeping roads out. Bear Swamp in the Huron-Manistee National Forest in Michigan is a wetland, and protecting it is critical. So many wetlands have been lost to development already. The Allegheny Front in the Allegheny National Forest in Pennsylvania is a place for hiking and camping, remarkable in the fall, and that experience would be ruined by logging. The agency built Alternative 3 specifically because commenters asked for protections for big game habitat, fisheries, and wildlife connectivity, then chose the alternative that protects none of it. The agency should explain that choice. The Forest Service held more than 600 public meetings and received 1.6 million comments before writing the 2001 rule. It has held none to undo it. My kids should not inherit fewer of these places than I did. Sincerely, [Your Name] [Your City, State]