Comment Analysis · Docket FS-2025-0001

FS-2025-0001-481058

Opposes rescissionA2 moderateSubstance 12/24Owed an answerPosted September 24, 2026 On Regulations.gov

In short: The comment documents that the agency's DEIS and Cost Benefit Analysis contain internal contradictions regarding bird abundance, wildfire ignition rates, and economic net present value that are not reconciled in the proposed rescission, and asserts a specific reliance interest in the roadless status of the Hermosa and Lizard Head 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

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

Wildlife Habitat
- “bird richness declines with road presence”
- “road-noise experiments... cut bird abundance by over a quarter”
- “birds of prey... depend on the quiet and the intact habitat”
Recreation Tourism Public Use
- “find solitude, peace, and myself”
- “hike and camp regularly”
- “recreation losses of at least $6.1 million a year”
Forest Management Wildfire
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “far higher fire density on roaded land than inside the affected roadless areas”
- “Building a road into a forest at high risk... could increase the incidence of human-caused fires”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent”
- “net present value spanning -$92 million to +$199 million”
- “Forest Service already carries a $6.9 billion road maintenance backlog”

What it names

National Forests: San Juan National Forest
Roadless areas: Hermosa

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The San Juan National Forest is where I find solitude, peace, and myself. I hike and camp regularly in the San Juan and in the Weminuche Wilderness, and I go looking for birds of prey that circle the high country and alpine lakes. I photograph grand mosaics of mountains, rivers, trees, and everything between. The Hermosa roadless area, 141,383 acres inside the San Juan, and the Lizard Head roadless area, 5,261 acres also in the San Juan, are part of that landscape. The proposed rescission of the 2001 Roadless Area Conservation Rule threatens what those places are and what they support, and I oppose it. The agency's own record documents what roads do to birds. The DEIS cites findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. The birds of prey I go looking for above the alpine lakes of the San Juan depend on the quiet and the intact habitat that roadless designation preserves. The agency has not explained how opening these areas to road construction squares with its own cited science. I ask that the agency address, in its final response, how the rescission is consistent with the bird abundance data its own DEIS presents. The proposal also invokes wildfire management as a justification, but the agency's own language cuts against that rationale. The DEIS 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." That finding comes from the agency's own record, not from opponents of the proposal. The agency must explain on the record why the proposal departs from its own prior findings on fire occurrence in roadless areas, and must 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 case for rescission is no stronger. The DEIS acknowledges 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 those marginal gains, the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year, set against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. The Forest Service already carries a $6.9 billion road maintenance backlog. The agency must reconcile the proposal with an economic analysis whose own range of outcomes includes significant net loss, and explain in plain terms how expanding a road system already in deficit is justified when the resource gains are, by the agency's own admission, fractions of national production. The regulatory flexibility analysis compounds this problem. The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. That certification is reached by spreading costs across every small firm in the sector nationally rather than examining the outfitters and guides who actually hold permits in the areas at issue. The agency should withdraw the certification and conduct an analysis focused on the small businesses operating in the potentially affected roadless areas, not on a national average that obscures the real distribution of harm. Finally, 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. This comment is such an interest. My use of the Hermosa and Lizard Head areas, the birds I go looking for there, and the photographs I take of those landscapes all rest on the expectation that roadless protections remain in place. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before any final action is taken. Sincerely, Alex Whittow Durango, Colorado