Comment Analysis · Docket FS-2025-0001

FS-2025-0001-541236

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

In short: The comment establishes that the proposed rescission of the 2001 Roadless Rule poses direct risks to private property, water supplies, and wildfire safety in New Mexico, specifically citing the Pecos Wilderness and Gila National Forest, and requests the agency withdraw the proposal.

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
    • “community water supplies”
    • “primary headwaters for critical rivers”
    • “compromising the clean water”
    • “water-scarce realities of the American Southwest”
  • Forest Management Wildfire
    • “threat of catastrophic wildfire”
    • “88% of wildfires start near roads”
    • “expands the primary ignition zones”
    • “hazardous fuels reduction treatments”
  • Recreation Tourism Public Use
    • “finest hunting, backcountry hiking, fishing”
    • “outdoor recreation economy”
    • “pristine backcountry experiences”
    • “dispersed recreation opportunities”
  • Wildlife Habitat
    • “fragment critical big game migration corridors”
    • “backcountry sporting havens”
    • “pristine national forest lands”

What it names

National Forests
Gila National Forest

The comment

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

I am writing to express my strong opposition to the proposed rule to rescind the 2001 Roadless Area Conservation Rule. As a New Mexico landowner and an avid outdoor enthusiast, I am deeply invested in the long-term health, safety, and productivity of our landscape. The proposal to strip protections from 1.6 million acres of pristine national forest lands in New Mexico poses direct risks to my property, our community water supplies, and our heritage. Please consider the following critical, region-specific points: • Downstream Watershed Impact: In New Mexico, water is life. Our roadless national forests act as the primary headwaters for critical rivers like the Gila, Rio Grande, and Pecos, which sustain our municipal drinking water, agricultural irrigation, and traditional acequias. For example, the roadless forests surrounding the Pecos Wilderness alone protect watersheds that provide 40% of the city of Santa Fe’s drinking water. Building new industrial roads will inevitably cause severe erosion, compromising the clean water that down-stream private landowners and municipalities depend on. • Increased Wildfire Risks Near Private Land: As a landowner, I am highly concerned about the threat of catastrophic wildfire. The Forest Service's claim that a total repeal will aid in fire management is heavily contradicted by federal wildfire statistics. Data shows that 88% of wildfires start near roads due to human activity and increased vehicle accessibility. Extending road networks deeper into wild public lands adjacent to private properties expands the primary ignition zones for human-caused blazes. Furthermore, the existing 2001 rule already grants local managers the authority to execute public safety tasks and hazardous fuels reduction treatments when necessary. • Preserving New Mexico’s Outdoor Economy: Our state’s roadless areas provide some of the finest hunting, backcountry hiking, fishing, and dispersed recreation opportunities in the country. Stripping protections from over 700,000 acres in the Gila National Forest alone would irreversibly fragment critical big game migration corridors and backcountry sporting havens. Our outdoor recreation economy is a vital economic driver supporting jobs statewide; industrializing these areas damages the pristine backcountry experiences that attract and sustain this growth. The national 2001 Roadless Rule has successfully protected our wild spaces for a quarter of a century. I urge the agency to look at the unique, water-scarce realities of the American Southwest and withdraw this proposed full rescission. Sincerely, Patricia Murphy Albuquerque/ Pecos, New Mexico

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