Comment Analysis · Docket FS-2025-0001

FS-2025-0001-571938

Opposes rescissionA1 strongSubstance 15/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment places on the record specific data regarding roadless acreage in Nevada and water intakes in the Intermountain region, cites 36 C.F.R. Section 294.12(b)(1),(3) to argue existing exceptions mitigate administrative burdens, and requests the agency quantify the expected increase in human-caused ignitions from new road access based on DEIS Table 21 data.

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

Recreation Tourism Public Use
- “Quiet, unpaved wilderness is what I live on Earth for”
- “Paddling through the Boundary Waters is an unmatched experience”
- “spend a good amount of my income to reach it”
Water Quality Quantity
- “1,466 municipal water intakes sit in watersheds containing affected roadless areas”
- “long-term economic costs of impairing crucial watersheds”
- “protect water quality at the source without the protections this rule provides”
Forest Management Wildfire
- “Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land”
- “human-caused ignitions increase in abundance with proximity to roads”
- “quantify the expected increase in human-caused ignitions from new road access”
Environmental Protection Biodiversity
- “Public land should be for the Earth”
- “for nature, for lichen and trees and wildlife that grow there”
- “value these places hold cannot be recovered once roads fragment them”

What it names

National Forests: Santa Fe National Forest
Law cited: 36 C.F.R. Section 294.12

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 Quiet, unpaved wilderness is what I live on Earth for. It is central to me spiritually, emotionally, and physically, and I spend a good amount of my income to reach it. The Santa Fe National Forest, the Boundary Waters, the Gila Wilderness, the Grand Canyon: the list goes on. Paddling through the Boundary Waters is an unmatched experience. People fly across oceans to do it, and I cross miles, too. I oppose the rescission of the 2001 Roadless Area Conservation Rule because what I depend on, and what the land itself depends on, is directly at risk. Public land should be for the Earth. It should be for nature, for lichen and trees and wildlife that grow there. That is not a sentimental position; it is a recognition that the value these places hold cannot be recovered once roads fragment them. The rule's rescission would erase that recognition without adequately answering the costs. The agency's justification rests partly on permitting and administrative burden, but the rule as written already contains the flexibility it claims is missing. The agency's own text states that it generally banned road building "subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." If the existing exceptions for public health, safety, mineral leases, and community wildfire protection already accommodate the situations the agency cites, the agency has not explained what specific burdens remain. I ask that the agency identify, by category and quantity on the record, which burdens are not already resolved by those existing provisions. On water, the Southwest's situation makes this rescission especially reckless. Nevada alone holds 316 inventoried roadless areas totaling 3,186,206 acres, and across the Intermountain region 1,466 municipal water intakes sit in watersheds containing affected roadless areas. We are already facing increasing drought pressures, and all science projects that we will continue to lose water. Nevada, California, and Arizona have recently lost access to Colorado River allocations. What are the long-term economic costs of impairing crucial watersheds against the short-term benefits of new roads? What are the financial projections for states already confronting diminished water supplies, and how does the agency expect those states to protect water quality at the source without the protections this rule provides? The agency must answer those questions in its final analysis. A close friend of mine is a firefighter who has risked their life to save communities from flames started along roads, with long-term health consequences from that work. I myself have had my job and life disrupted by having to flee from wildfire. The agency's own data make the connection explicit: "Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads." Given that the effects analysis concedes road access could increase the number and frequency of wildfires, I ask that the agency quantify the expected increase in human-caused ignitions from new road access and weigh it transparently against the claimed reduction in wildfire hazard, rather than leaving that calculation unresolved.