Comment Analysis · Docket FS-2025-0001

FS-2025-0001-572653

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

In short: The comment establishes that the agency's DEIS and Cost Benefit Analysis contain internal contradictions regarding wildfire risks, wildlife conflicts, and economic net benefits that undermine the rationale for rescinding the Roadless Area Conservation Rule, and requests specific reconciliation of these data points.

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
    • “moose are drawn to road corridors for road salt”
    • “increased contact and conflict that come with open roads in grizzly habitat”
    • “recovery of deer and moose populations by preserving old-growth winter shelter”
  • Forest Management Wildfire
    • “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
    • “Roads would not improve our response; these fires are too big, too quickly”
    • “reconcile the rescission with the ignition data in DEIS Table 21”
  • Economic Impact Fiscal
    • “total timber volume affected by this rule is less than 0.5 percent of total United States production”
    • “recreation losses of at least $6.1 million a year”
    • “expanding a road system already carrying a $6.9 billion maintenance backlog”
  • Cultural Heritage Indigenous
    • “looting of the historic sites and buildings I photograph”
    • “photograph the historic buildings out on the forest”

What it names

National Forests
Medicine Bow-Routt National ForestRoutt National Forest
Roadless areas
Black Mountain
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 knowledgeAnalytical gapEvidenceRequest

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Living near the Routt National Forest when the original roadless rule was passed shaped how I think about these lands. I go to the forest to reset, to forage, and to share with my kids. I used to ride trails near Steamboat. I go out looking for moose, bears, sandhill cranes, owls, you name it. I love to photograph the historic buildings out on the forest. Black Mountain, in the Medicine Bow-Routt National Forest, is a place I know to hold mushrooms and other resources that deserve protection. This comment opposes the rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001). The agency's own record undermines its wildfire rationale. The DEIS states: "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." I have been evacuated twice for fires. Roads would not improve our response; these fires are too big, too quickly. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence and fuel treatment in roadless areas, and that it reconcile the rescission with the ignition data in DEIS Table 21, which the agency's own analysis shows reflects far higher fire density on roaded land than inside the affected roadless areas. More roads also threaten the wildlife I go out looking for. The DEIS notes that moose are drawn to road corridors for road salt, which increases human-moose interactions and conflict. The DEIS separately quotes the federal grizzly recovery plan on bears: increased contact and conflict that come with open roads in grizzly habitat can ultimately end in grizzly mortality, and shooting, habituation and food reward all increase with the use of even secondary unpaved roads. Beyond conflicts with individual animals, the agency's own Tribal record credits the rule's protection with the recovery of deer and moose populations by preserving old-growth winter shelter. I also know from my own time out there that more roads mean more looting of the historic sites and buildings I photograph. The agency needs to explain how opening the road system addresses any of these documented harms rather than compounding them. The economics do not support rescission either. The agency's own record states: "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 Forest Service cannot manage the roads it already has as system roads; I ask that the agency reconcile the proposal with its own Cost Benefit Analysis, which projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year, and a net present value spanning -$92 million to +$199 million, and explain how expanding a road system already carrying a $6.9 billion maintenance backlog can be justified when the agency's own analysis cannot establish a net benefit. The proposal also misrepresents how restrictive the current rule actually is. The rule as written already states 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)." The original purpose of the Forest Service was to protect resources, and the existing exceptions already cover the situations the agency claims the rule prevents. Which specific burdens are not already addressed by those exceptions, and why has the agency not quantified them? Finally, the regulatory flexibility certification does not hold up. "The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year." Spreading an annual expenditure loss across every small firm nationally rather than assessing the outfitters and guides actually holding permits in the affected areas is not an honest analysis. The agency should withdraw that certification and assess impact on the small entities actually operating in these roadless areas. The agency has to answer why this rescission is needed, when so much work was done to put the original roadless rule in place. Sincerely, R. Morris Colorado

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