Comment Analysis · Docket FS-2025-0001

FS-2025-0001-533433

Opposes rescissionA0 noneSubstance 7/24Posted October 4, 2026 On Regulations.gov

Exact copy — Byte-identical to another submission. This comment stands for 2 submissions in its group.

In short: The comment establishes the commenter's direct recreational use of specific national forests and wilderness areas in Colorado, Wyoming, and Arizona, and documents opposition to the rescission of the Roadless Rule based on cited DEIS findings regarding habitat fragmentation, water quality, and wildfire proximity to roads.

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

Environmental Protection Biodiversity
- “protects intact ecosystems for American wildlife”
- “habitat for vulnerable wildlife species, including the Canada Lynx”
- “habitat fragmentation reduces biodiversity”
- “bird richness declines with road presence”
Water Quality Quantity
- “Roads cause excessive erosion and siltation to streams”
- “protects our valuable drinking water”
- “Roadless areas help keep invasive species at bay and prevent pollution”
Recreation Tourism Public Use
- “avid hiker, walker, bicyclist, Nordic and downhill skier, camper and birder”
- “spend a ton of time every year recreating on public lands”
- “economic boon for tourism”
- “walk to the Sangre de Cristo Wilderness from my home”
Forest Management Wildfire
- “It is false that building more roads will help fight wildfires”
- “90% of wildfires happen within 1/4 mile of roads”
- “more roads do not lead to better forest health”

What it names

National Forests: Bighorn National Forest Coronado National Forest Rio Grande National Forest San Juan National Forest
Roadless areas: Snowy RangeSpring Creek

The comment

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

October 3, 2026 Comments on the proposal to rescind the Roadless Area Conservation Rule. Docket # FS-2025-0001. My name is Suzanne DeVore and I live in Mosca, Colorado at zip code 81146. I am a voter. I am an avid hiker, walker, bicyclist, Nordic and downhill skier, camper and birder. I spend a ton of time every year recreating on public lands. It is my understanding that despite 99% public opposition to its rollback, the Administration moved forward with its intent to rescind the 2001 Roadless Rule by publishing a Draft Environmental Impact Statement (DEIS). I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I strongly support Alternative 1, the No Action alternative. I love spending time in the National Forests near where I live in southern Colorado. Including the Rio Grande National Forest, the San Juan National Forest, the Gunnison National Forest and the San Isabel National Forest. I am fortunate to be able to walk to the Sangre de Cristo Wilderness from my home. I also spend weeks camping in the neighboring state of Wyoming. I particularly love the Medicine Bow National Forest and the dramatic Snowy Range in southern Wyoming. I also love to camp in the Bighorn National Forest and backpack in the Wind River Range. My husband is an avid fly-fisherman, so this determines a lot of the places we visit! We like to travel to the Coronado National Forest in Arizona for hiking and cycling during the winter. We particularly love the areas in and around the Chiricahua mountains. This proposal is just ludicrous for many reasons, but mainly because the current road system is stressed now! The U.S. Forest Service lacks the capacity, in funds and workforce, to support its existing roads, much less an increased inventory of roads. There are plenty of roads now. Roads cause excessive erosion and siltation to streams. Most of America's clean, fresh watersheds start in national forests. In this time of changing climate and severe droughts the current rule protects our valuable drinking water. Roadless areas help keep invasive species at bay and prevent pollution. The DEIS details many points on this topic. The current rule protects intact ecosystems for American wildlife. Roadless areas provide habitat for vulnerable wildlife species, including the Canada Lynx in our area. These roadless landscapes, often adjacent to other protected areas, like wilderness, are critical for habitat connectivity and health. Roads severely impact birds and wildlife. The DEIS cites the findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird variety and abundance. It is vital to avoid fragmentation of the roadless areas. The DEIS cites the finding that habitat fragmentation reduces biodiversity. Wildlife tend to disappear when forest cover thins; many avoid roads used by winter machines. The DEIS notes that wide-ranging mammals like the grizzly bear “have suffered habitat loss and the extirpation or fragmentation of their populations.” It is false that building more roads will help fight wildfires. Studies show that more roads do not lead to better forest health through increased fire-management activity. Conversely, Wildfire incidents happen near roads. Studies show that 90% of wildfires happen within 1/4 mile of roads. If more roads led to more fires, this action would increase the number of incidents, not improve response, as suggested. Our National Forests sustain some of our nation’s last stands of old growth forest. Here in Colorado our nearby Rio Grande National Forest and all the national forests across the United States are an economic boon for tourism and for well-planned and regulated timber sales. No new roads are required to support these benefits of the forest. It is widely recognized that the purpose of changing the roadless rules has nothing to do with forest health as it is proclaimed to do. The purpose is to reduce regulatory burden and return decision making to local officials, not U.S. Forest Service experts with years of education and experience managing our forests for all U.S. citizens. This proposal is a callous, greedy attempt to provide access to our public lands for oil, mining, timber and other extractive industries! It’s sacrificing our forests to make a few wealthy elite people richer. It would bring short-sighted and short-term benefits to these few, while ruining long-term, irreplaceable lands that belong to all of us, the public. I completely oppose the proposal to rescind or alter the Roadless Rule, and strongly support Alternative 1, the No Action alternative. Suzanne DeVore 113 Spring Creek Drive Mosca, CO 81146