Comment Analysis · Docket FS-2025-0001

FS-2025-0001-445585

Opposes rescissionA2 moderateSubstance 8/24Owed an answerPosted September 18, 2026 On Regulations.gov

In short: The comment places on the record specific data regarding wildfire likelihood, economic losses, and maintenance backlogs, while documenting the procedural deficiency of failing to conduct adequate government-to-government consultation and the specific need for an ANILCA Section 810 subsistence analysis.

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.

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

Environmental Protection Biodiversity
- “preservation of numerous imperiled species”
- “protects millions of acres of public land from destruction”
- “ecologically fragile place”
Tribal Sovereignty
- “failure to fulfill its trust responsibilities”
- “adequate government-to-government consultation”
- “threaten sacred sites, traditional gathering areas”
Climate Carbon Storage
- “as carbon sinks”
- “global climate significance of the forest as a critical carbon sink”
Recreation Tourism Public Use
- “places for humans to seek quietude”
- “tradeoffs with opportunities for quiet, remote and self-reliant recreation”
- “psychological solace such places provide humans”

What it names

National Forests: Gila National Forest

The comment

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

To Whom It May Concern: I would like to go on the public record in opposition to the rescission of the 2001 Roadless Rule. The Roadless Rule is a piece of legislation that protects millions of acres of public land from destruction. Doing away with this Rule is an ill-conceived idea. I am one of millions of Americans that value and respect protected forest land. This public land was set aside by our forebears for the preservation of numerous imperiled species, as carbon sinks and as places for humans to seek quietude apart from an increasingly urbanized world. The ecological & economic value & the psychological solace such places provide humans is immeasurable. The proposed rescission itself delineates numerous reasons to NOT rescind the Roadless Rule. 1) Roads increase the likelihood of wildfires. Where roads exist in forests, wildfires are four times more likely than in areas lacking roads. "Greater public access can increase human-caused ignition potential in some locations." 2) "This [proposed] expansion could increase road-based recreation and accessibility improvements but would result in tradeoffs with opportunities for quiet, remote and self-reliant recreation and may increase user conflicts and result in lost economic benefits. Losses in economic benefit to recreationists are most likely to be associated with the operable areas of current IRAs and could be an estimated $6.1 million annually." 3) "Any efficiency gains [of the proposed rescission] are expected to be incremental and limited by road costs, maintenance funding gaps, and the $6.9 billion deferred maintenance backlog for roads and bridges." 4) "According to the majority Tribal sentiment, a central procedural concern is the Federal Government's failure to fulfill its trust responsibilities by proceeding without adequate government-to-government consultation. Tribes consistently argued that removing this layer of national protection shifts the unsustainable burden of project-level review onto their limited resources and exposes previously untouched areas to industrial activity, mining interests, and destructive recreational access, all of which threaten sacred sites, traditional gathering areas, water quality, and subsistence resources. Proposed alternatives that were frequently requested included retaining the existing rule (“No Action”) or establishing new co-management structures, such as a “Strengthened Roadless Rule Alternative” or a “Traditional Homelands Conservation Rule” that integrates Traditional Ecological Knowledge, Tribal co-stewardship, and Tribal consent for major decisions. For ancestral lands in Alaska, representatives stressed the need for a comprehensive ANILCA Section 810 subsistence analysis prior to any decision and noted the global climate significance of the forest as a critical carbon sink." For me personally, the impact of the proposed rescission would be sizable. I live on the edge of the Gila National Forest, which stands to bear the brunt of the negative impact for the state of New Mexico. The Gila National Forest contains 45% of the state's proposed affected land. Such a change to this ecologically fragile place--the first area in the world set aside for federal protection from development-- is untenable. The proposed change is antiquated & totally unnecessary. Please keep the Roadless Rule intact. It is not hyperbolic to say that humanity depends on it.