Comment Analysis · Docket FS-2025-0001

FS-2025-0001-475793

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

In short: The comment establishes that the agency's DEIS contains internal contradictions regarding wildfire ignition risks, elk survival rates, and habitat fragmentation impacts that have not been reconciled, and documents the commenter's specific reliance interests in the 2001 Roadless Rule for hunting, hiking, and fishing in unroaded Western National Forests.

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.

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

Forest Management Wildfire
- “human caused ignitions increase in abundance with proximity to roads”
- “risk of ignition is about 5 times greater next to a road”
- “Opening roadless areas to road construction does not reduce ignition risk. It multiplies it.”
- “reconcile increased risk of wildfire by allowing increased road construction”
Wildlife Habitat
- “elk and other animals move and survive”
- “elk survival rates increased during a road closure and decreased when the gates were removed”
- “elk avoid roads and select unroaded habitat”
- “project the effects of the proposed rescission on big game populations”
Environmental Protection Biodiversity
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
- “adverse impacts to biodiversity based on their own findings”
- “apply the cited fragmentation range to the full 40.1 million acres”
- “intact habitat holds more of what makes wild country worth going to”
Recreation Tourism Public Use
- “Enjoying nature, hiking, backpacking and occasionally hunting and fishing”
- “hike and climb away from the sound or sign of motorized travel”
- “fishing without motorized travel”
- “hunting, for hiking and backpacking in National Forests across the West”

What it names

Works cited: Narayanaraj and Wimberly 2012

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequestLegal

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Enjoying nature, hiking, backpacking and occasionally hunting and fishing has meant something real to me across most of my life, and the country animals depend on is not abstract. It is the unroaded terrain where elk and other animals move and survive, where I can hike and climb away from the sound or sign of motorized travel. The National Forests across the West are where I go for that. The proposal to rescind the 2001 Roadless Area Conservation Rule would put those experiences at risk, and the agency's own record gives reasons to deny the rescission that the agency has not answered. The justification leans in part on wildfire and fuels management, but the agency's own prior findings run the other direction. The DEIS states plainly: "Consistent with other research findings, these analyses indicate that human caused ignitions increase in abundance with proximity to roads, supporting the notion that roads facilitate human access, which can in turn result in more human caused fires (Narayanaraj and Wimberly 2012, Parisien et al., 2016, Balch et al., 2017, Chen and Jin, 2022)” with Table 26 suggesting that the risk of ignition is about 5 times greater next to a road than a mile or more away. Opening roadless areas to road construction does not reduce ignition risk. It multiplies it. The agency must explain why the current proposal departs from that finding, and must reconcile the rescission with the ignition data in its own DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. That reconciliation belongs in the record. My ability to hunt and view animals as well as their survivability is tied directly to the character of the land they use. The DEIS acknowledges this connection and then walks away from it. The record states: "The DEIS cites the finding that elk survival rates increased during a road closure and decreased when the gates were removed (Cole 1997), and that elk avoid roads and select unroaded habitat." The agency cites that finding and then projects no population-level effect on big game anywhere in the document. That is not analysis. The agency must project the effects of the proposed rescission on big game populations and on hunter opportunity across the affected landscape, and must address those projections in the final rulemaking. Hiking to a lake or peak in a wild place, without motorized travel, is a smaller version of the same principle: intact habitat holds more of what makes wild country worth going to. The DEIS’s own Conclusions recognizes that the Alternatives could have adverse impacts to biodiversity based on their own findings and quantifies what fragmentation does to that: "The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent." That range is significant. It appears in the record and then disappears. No projection applies it to the 40.1 million acres of potentially affected environment. A range of 13 to 75 percent means something very different at scale, and the agency has a responsibility to work through what it means here. I ask that the agency apply the cited fragmentation range to the full 40.1 million acres before it finalizes any action. Finally, the agency has invited comment on reliance interests and then declined to weigh them. The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. My interest is this: I have organized how I hunt, hike, climb, fish and experience nature around the existence of this rule. The wild places I depend on for fishing without motorized travel, for hunting, for hiking and backpacking in National Forests across the West, exist in the form they do because the 2001 rule has held. That is a reliance interest the agency invited, created, and has not assessed. Under settled administrative law, an agency changing course must grapple with the reliance its prior policy generated. This comment is a record of that reliance. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before it takes any final action. To conclude, I maintain that the agency’s own document (DEIS) provides reasons to deny recission of the roadless rule. The agency must reconcile increased risk of wildfire by allowing increased road construction with suppression of wildfires by having road access, provide an analysis of the effects of the proposed rescission on big game populations and on hunter opportunity across the affected landscape factoring in biodiversity loss and not solely increased road access, and apply the cited range of potential habitat fragmentation across the full 40.1 million acres covered by the roadless rule to assess the full impact of the alternatives. Sincerely, William Rice Colorado