Comment Analysis · Docket FS-2025-0001

FS-2025-0001-562617

Opposes rescissionA0 noneSubstance 8/24Posted October 5, 2026 On Regulations.gov

In short: The comment establishes that the commenter resides adjacent to the Cibola National Forest and Sandia Mountain Wilderness in New Mexico, and opposes the removal of the Roadless Rule based on cited evidence that roads increase wildfire risk, existing road maintenance costs are unsustainable, and roadless areas provide critical habitat.

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

  • Forest Management Wildfire
    • “wildfire management will not be improved and that wildfires will in fact increase”
    • “Wildfire risk is documented to be higher in areas with roads”
    • “fire mitigation status of the national forests are of critical interest”
  • Economic Impact Fiscal
    • “repealing the Roadless Rule would be fiscally irresponsible”
    • “roads that the Forest Service already is responsible for needed $8.6 billion in maintenance”
    • “irresponsible to build further roads when the ones already in existence cannot be maintained”
  • Wildlife Habitat
    • “animals rely on these areas without roads”
    • “leave 2% of the ecosystem intact”
    • “further reduction of crucial habitat”
  • Recreation Tourism Public Use
    • “first choice for recreation is always to enjoy the public recreation lands”
    • “We hike, backpack, fish, hunt, cross country ski, downhill ski, camp, and mountain bike”
    • “Our recreational use of the national forest... may both be impacted by wildfires”

What it names

National Forests
Cibola National Forest
Works cited
Cardille et al. 2001

Attachments

1 file. Counts as 1 — Counts as one: The attachments enclose no one else's submissions; the comment counts as one.

  • Own letter

The comment

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

I live in New Mexico and my family of six’s first choice for recreation is always to enjoy the public recreation lands that are abundant in the state. We hike, backpack, fish, hunt, cross country ski, downhill ski, camp, and mountain bike. In addition, our house is one undeveloped lot removed from the Cibola National Forest and about a half mile from the Sandia Mountain Wilderness area, so the fire mitigation status of the national forests are of critical interest for us. I am attaching a view of our neighborhood from Cibola National Forest. I am commenting to oppose the removal of the Roadless Rule. My family’s main concern with the removal of the Roadless Rule is that wildfire management will not be improved and that wildfires will in fact increase. Wildfire risk is documented to be higher in areas with roads (1, 2). Furthermore, according to a white paper by Trout Unlimited (3) the portion of current Roadless Rule areas that have been treated for wildfire mitigation (3.5%), while less than the managed areas with roads (4.5%), is 75% of the managed area with roads so the lack of roads is not impacting forest management too significantly. Our recreational use of the national forest and the safety of our home may both be impacted by wildfires in the future, so these two facts together are the primary driver of my opposition to repealing to Roadless Rule. Secondly, repealing the Roadless Rule would be fiscally irresponsible. The roads that the Forest Service already is responsible for needed $8.6 billion in maintenance (4) as of 2023; it is irresponsible to build further roads when the ones already in existence cannot be maintained with current budgets. Finally, animals rely on these areas without roads. They constitute only 30% of the Forest Service managed area, and only 2% of the total land area of the United States. Surely we can leave 2% of the ecosystem intact? Given the above facts, I surmise the only motivation to remove the rule is to open up those small areas of the country that we have not already exploited for further extraction of resources to make money. This is not good stewardship of the land or resources. In conclusion, please do not remove the Roadless Rule, it will lead to increased wildfire risks, less maintenance on already existing roads, further reduction of crucial habitat, and money to further line the pockets of those who thrive off of the exploitation of the earth. 1.Cardille, J.A.; Ventura, S.J.; Turner, M.G., 2001. Environmental and social factors influencing wildfires in the Upper Midwest, United States. Ecological applications, 11(1), pp.111-127. 2. Aplet, G.H.; Hartger, P; Dietz, M.S., 2026. Three-decade record of contiguous – U.S. national forest wildfires indicates increased density of ignitions near roads. Fire Ecology, 22:8. 3. Roadless Active Management and Fire: A GIS data analysis and research review, Trout Unlimited, 2026 4. Maintaining Infrastructure https://www.fs.usda.gov/science-technology/infrastructure/maintaining

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