Comment Analysis · Docket FS-2025-0001

FS-2025-0001-453815

Opposes rescissionA0 noneSubstance 7/24Posted September 21, 2026 On Regulations.gov

In short: The comment establishes that the proposed repeal of the Roadless Area Conservation Rule is arbitrary and capricious because it ignores data showing that 90% of wildfires occur near roads, fails to account for the 850% increase in erosion and resulting water quality degradation, and overlooks the adverse economic impacts on specific Colorado communities such as those near the Eagle’s Nest, Holy Cross, Weminuche, and Sangre de Cristo areas.

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

A0 none: Counted, not answered.

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.
Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
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.
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.

Topics

Water Quality Quantity
- “preserves the purity of drinking and irrigation water”
- “water from our wilderness areas drains into the Colorado River”
- “send silt into the various reservoirs that hold water for drinking and irrigation”
- “poor water quality”
Forest Management Wildfire
- “90% of wildfires occur within 1/2 mile of a road”
- “Elimination of roadless areas will, in fact, increase the risk of wildfires”
- “increased wildfire risk”
- “repealing the roadless rule would not accomplish the stated goal of wildfire reduction”
Economic Impact Fiscal
- “drive a tourism industry that contributes over $29 billion to our economy”
- “Small businesses such as fly-fishing shops, restaurants, outdoor equipment retailers and lodging providers will suffer greatly”
- “devastation to local economies”
- “adversely impact on the tourism economies near these wilderness areas”
Climate Carbon Storage
- “Old growth forests... provide one of the most effective means we have for capturing carbon”
- “Tongass National Forest has been called one of the most productive carbon-trapping forests on earth”
- “increased atmospheric carbon”

What it names

National Forests: Tongass National Forest

The comment

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

Brooke Rollins Secretary of Agriculture 1400 Independence Avenue, SW. Washington, DC 20250 RE: Keep the Roadless Area Conservation Rule Docket ID FS-2025-000, RIN 0596-AD66 Dear Sec. Rollins: Since 2001 the roadless rule has protected millions of acres of some of the most beautiful, scenic and ecologically important land in the United States. I write to urge you to keep those protections in place; do not rescind the roadless rule. For purposes of this document, I will use “roadless” and “wilderness” interchangeably, as our roadless areas are generally named “wilderness” (e.g., Holy Cross Wilderness) Here in Colorado the roadless rule helps protect against wildfires, preserves the purity of drinking and irrigation water for Coloradans and those in downstream states (including your own home state of Texas), helps drive a tourism industry that contributes over $29 billion to our economy and provides habitat for thousands of different species. One of the stated reasons for repealing the roadless rule is the alleged benefit of wildfire mitigation. Wildfires are, of course, a major danger here in Colorado and the entire western US. However, all the data shows that 90% of wildfires occur within ½ mile of a road. Elimination of roadless areas will, in fact, increase the risk of wildfires. Therefore, such an action would be in willful disregard of the facts and would be arbitrary and capricious. Significant amounts of the water used for drinking and agriculture here in Colorado starts as snowpack and rainfall in wilderness areas. Moreover, these areas serve as water sources for our neighboring states. Texas, Oklahoma, Kansas and Nebraska all use water from wilderness areas in the Front Range of our Rocky Mountains. To the west, the water from our wilderness areas drains into the Colorado River. As I am sure you are aware, the Colorado River is in crisis and we are rapidly approaching the point where those with lower priority water rights, such as the state of Arizona, could see their water reduced or even cut off. Other areas that rely on Colorado River water for hydroelectric power, like Las Vegas, may soon go dark. Areas with logging roads, as contemplated by this rule change, have up to 850% more erosion than undisturbed habitat. Not only would this erosion damage the fisheries here in Colorado – and damage our tourism economy – it will send silt into the various reservoirs that hold water for drinking and irrigation, compounding the serious problems we see in water storage facilities and reservoirs throughout the Southwest. This silt already reduces the available storage capacity for water. Repealing the roadless rule will further exacerbate the existing crisis. The repeal of the roadless rule makes no provision for all those who will be adversely impacted by this action, including consumers and farmers. It is, therefore, arbitrary and capricious. The repeal of the roadless rule would adversely impact on the tourism economies near these wilderness areas. I can testify that I, personally, spent a good deal of money in areas near the Eagle’s Nest, Holy Cross, Weminuche, and Sangre de Cristo areas this year alone. Small businesses such as fly-fishing shops, restaurants, outdoor equipment retailers and lodging providers will suffer greatly from the reduction in scenic value, fishing and watershed degradation and increased wildfire risk. Not accounting for the economic impact on these small businesses and small towns would be arbitrary, capricious and, I should add, cruel to those who live in these places. Old growth forests, such as those protected by the roadless rule, provide one of the most effective means we have for capturing carbon and reducing greenhouse gases. The Tongass National Forest has been called one of the most productive carbon-trapping forests on earth. That protection comes in large measure from the roadless rule. As you can see, repealing the roadless rule would not accomplish the stated goal of wildfire reduction. However, we would see increased atmospheric carbon, poor water quality, damage to reservoirs, devastation to local economies and an increased risk of wildfires. The proposed repeal of the rule is arbitrary and capricious, and I urge you to reject it. Yours most sincerely and respectfully, Michael J. Sexton