Comment Analysis · Docket FS-2025-0001

FS-2025-0001-544104

Opposes rescissionA1 strongSubstance 15/24Owed an answerPosted October 4, 2026 On Regulations.gov

In short: The comment documents that the agency's DEIS contains internal contradictions regarding wildfire ignition rates on roaded versus unroaded lands, wildlife survival dependencies on roadless habitat, and economic net benefits, while citing a Tenth Circuit ruling that upheld the 2001 Roadless Area Conservation Rule, thereby establishing a basis for requesting the withdrawal of the proposed rescission.

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

A1 strong: Must be answered — it names the law.

Owed an answer on Analytical gap, Evidence, Legal.

Standard dismissals it defeats

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.
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.
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.

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.
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.

Topics

Wildlife Habitat
- “Elk, deer and bear can be found there all year long, and it should be protected at all costs”
- “elk avoid areas near roads and select unroaded habitat for summer cover and forage”
- “roads built for resource extraction may have altered mule deer migration routes”
- “increased contact and conflict that come with open roads can ultimately end in grizzly mortality”
Water Quality Quantity
- “part of the headwaters of the Colorado River, which supplies water to 40 million people”
- “325 municipal water intakes sit in watersheds containing affected roadless areas”
- “Roads increase sedimentation and degrade those watersheds”
Recreation Tourism Public Use
- “I run day trips across some of Colorado's most technical 14ers”
- “photograph action sports, including skiing, climbing, biking and running”
- “provides a little respite from the noise and bustle of I-70”
- “recreation losses of at least $6.1 million a year”
Legal Regulatory Framework
- “A federal court of appeals considered that exact argument and held otherwise”
- “The Tenth Circuit's ruling was unambiguous”
- “The agency should state plainly what legal basis it now believes supports a contrary position”

What it names

National Forests: White River National Forest
Roadless areas: Rocky Mountain
Law cited: 28 U.S.C. Section 1291

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Elk Mountains are where I spend my summers. I run day trips across some of Colorado's most technical 14ers carrying nothing but a day pack and some running shoes. I also photograph action sports, including skiing, climbing, biking and running, and so much of that work takes place in roadless areas. What I am fighting for in this comment is not abstract. I live very near East Creek B, a 7,178-acre roadless area in the White River National Forest, and I love exploring the old trails that run all around the ridges and valleys there. Elk, deer and bear can be found there all year long, and it should be protected at all costs. I am asking this agency to withdraw the proposed rescission of the 2001 Roadless Area Conservation Rule. Grizzly Creek, 6,612 acres also in the White River, provides a little respite from the noise and bustle of I-70 passing through Glenwood Canyon. The trail takes you back into the hills, where you can loop over a remote pass and connect back to the bottom of the canyon. That area was hit by a fire several years ago and is still in the process of recovery. Any road construction in this area would cause permanent and irreversible damage to an ecosystem just bouncing back from catastrophe. The agency's own record agrees with the logic of that concern: "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." If the agency's justification for rescission includes better fuels management, I ask that it explain why it departs from these findings and reconcile the proposal with the ignition data in DEIS Table 21, which its own record shows reports far higher fire density on roaded land than inside the affected roadless areas. The wildlife I see in East Creek B depends on these protections. The agency's own DEIS record, citing Rowland, Unsworth, and Cole, found that elk avoid areas near roads and select unroaded habitat for summer cover and forage, and that elk survival rates rose during a road closure and fell again when the gates were removed. For deer, the agency's own analysis cites research finding that roads built for resource extraction may have altered mule deer migration routes and increased their movement speed, disrupting the unroaded security these animals depend on. On bear, the DEIS draws on the federal grizzly recovery plan and states that the increased contact and conflict that come with open roads can ultimately end in grizzly mortality, and that shooting, habituation and food reward all increase with the use of even secondary unpaved roads. The agency should address in this proceeding what specific countervailing wildlife finding supports removing protections that its own science says are keeping these animals alive. The White River National Forest is the most visited national forest in Colorado and part of the headwaters of the Colorado River, which supplies water to 40 million people in seven states and Mexico. Across the Rocky Mountain region, 325 municipal water intakes sit in watersheds containing affected roadless areas. Roads increase sedimentation and degrade those watersheds. I want the agency to explain how the rescission accounts for those downstream consequences. The economics of this proposal do not hold up. The agency's own record states 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." The agency's own cost-benefit analysis projects timber revenue of $5.2 to $11.4 million a year to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. The agency must explain how an action whose own analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog. Finally, on authority: the agency suggests the 2001 rule exceeded its statutory power. A federal court of appeals considered that exact argument and held otherwise. The Tenth Circuit's ruling was unambiguous: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction. The agency should state plainly what legal basis it now believes supports a contrary position. The places I named here are real. The trails exist. The animals are there. The rescission should not proceed. Sincerely, Sky Couvreux Redstone, CO