Comment Analysis · Docket FS-2025-0001

FS-2025-0001-475463

Opposes rescissionA2 moderateSubstance 15/24Owed an answerPosted September 23, 2026 On Regulations.gov

In short: The comment establishes that the agency's proposal to rescind the Roadless Area Conservation Rule is inconsistent with its own DEIS findings regarding wildfire risk on roaded lands, fails to reconcile the economic costs of road maintenance with projected benefits, and violates NEPA by dismissing protective alternatives based on deregulatory mandates rather than environmental analysis, specifically impacting the San Miguel and Dolores River watersheds in Colorado.

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, 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

Water Quality Quantity
- “Roads change hydrology, increase erosion, and degrade the water quality”
- “325 municipal water intakes sit in watersheds containing affected roadless areas”
- “paddlers and downstream communities depend on”
Forest Management Wildfire
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “Adding more roads to a region already experiencing these fires poses a much larger risk”
- “reconcile the rescission with the ignition data in its own DEIS”
Governance Policy Process
- “Alternatives with more protection were dismissed as not responsive to the deregulatory executive orders”
- “A purpose written as deregulation forecloses the comparison NEPA requires”
- “The agency must restate the purpose and need in terms of actual forest conditions”
Economic Impact Fiscal
- “The agency is already $6.9 billion behind on maintaining the roads it has”
- “recreation losses of at least $6.1 million a year”
- “net present value spanning -$92 million to +$199 million”

What it names

Roadless areas: Rocky MountainSan Miguel

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeEA analysisAnalytical gapEvidenceRequestAlternativeLegal

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The San Miguel and Dolores Rivers run through some of the most intact country left in Colorado, and I have spent the past decade visiting the Tabeguache and the Cimarron on the Grand Mesa-Uncompahgre-Gunnison National Forest. Losing these spaces would be devastating for the people of Colorado and the people of the West. I oppose the rescission of the 2001 Roadless Area Conservation Rule. Public lands should be managed to protect them for future generations. That principle is directly at stake here, and I want to address what I have seen and what the agency's own record shows. I paddle the San Miguel and Dolores Rivers and their tributaries. Those rivers drain the kind of unroaded country this rule protects. Roads change hydrology, increase erosion, and degrade the water quality that paddlers and downstream communities depend on. Colorado holds 326 inventoried roadless areas totaling 4,407,277 acres, and across the Rocky Mountain region 325 municipal water intakes sit in watersheds containing affected roadless areas. That is not an abstraction. It is the water in these valleys. The wildfire situation in the Cimarrons is not abstract either. I have watched wildfires rage around the Cimarrons this past summer. It took extensive resources to keep homes and communities safe. The agency argues that rescission supports fuel management, but its own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." Adding more roads to a region already experiencing these fires poses a much larger risk to wildfires spreading and posing a greater threat. The agency must explain why this proposal departs from its own prior findings, and it must reconcile the rescission with the ignition data in its own DEIS, which reports far higher fire density on roaded land than inside affected roadless areas. The fire rationale also does not match the stated legal basis for this action. The agency's own record acknowledges: "The purpose and need is to reduce regulatory burden and return decisionmaking to local officials. Overlap with the wildland-urban interface as defined by HFRA is 9.8 million acres, 24 percent of the affected area, and the DEIS says the benefits of added fuel-management access 'would likely be modest and localized.'" The agency built and then rejected a WUI-targeted alternative that would have answered the fire rationale without nationwide rescission. Why was that alternative discarded in favor of a blanket rollback? The agency has not answered that question. On the economics: it absolutely does not make sense to spend more money constructing roads when existing roads cannot be maintained. Southwestern Colorado is already experiencing mudslides and environmentally destructive events more and more often. The Forest Service cannot maintain roads, bridges, and access points in the appropriate timeframe, and the USFS in our region will not be able to manage more roads and more terrain going forward. The agency is already $6.9 billion behind on maintaining the roads it has, against a road budget of about $73 million a year. The agency's own record states: "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." The agency must reconcile the proposal with its own cost-benefit analysis, which projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million, and explain how an action whose own numbers cannot establish a net benefit justifies expanding a road system already collapsing under deferred maintenance. Finally, the alternatives analysis is broken at its foundation. The agency's record acknowledges: "Alternatives with more protection were dismissed as not responsive to the deregulatory executive orders, and the keep-boundaries option was cut because it 'would continue to restrict local decision-making discretion' and because analysing roadless values is 'an administrative and legal burden for the agency.'" A purpose written as deregulation forecloses the comparison NEPA requires. The agency must restate the purpose and need in terms of actual forest conditions and analyze at least one fully protective alternative before this rulemaking proceeds further. The Tabeguache and the Cimarron matter. The rivers that run out of them matter. Protect them. Sincerely, Marisa Marshalka Telluride, CO 81435