Comment Analysis · Docket FS-2025-0001

FS-2025-0001-583131

Opposes rescissionA1 strongSubstance 18/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment documents the commenter's reliance interest based on prior Forest Service employment in Carson National Forest and Taos, and identifies specific deficiencies in the agency's analysis regarding wildfire ignition data (DEIS Table 21), economic net benefits, and the failure to quantify administrative burdens or weigh reliance interests as solicited in the Federal Register notice.

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

Water Quality Quantity
- “available clean water”
- “water quality protection roadless areas provide”
- “739 municipal water intakes sit in watersheds containing affected roadless areas”
- “without the water quality protection roadless areas provide, the town itself is at risk”
Forest Management Wildfire
- “roads increase fire risk because they increase human activity”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “Repealing it and permitting additional traffic and logging will increase ignition risk”
- “reconcile the rescission with the ignition data in its own DEIS Table 21”
Economic Impact Fiscal
- “The financial case for rescission does not hold together”
- “shortage of funds to manage existing roads”
- “recreation losses of at least $6.1 million a year”
- “expanding a road system already carrying a $6.9 billion maintenance backlog”
Legal Regulatory Framework
- “this comment is itself a reliance interest”
- “The agency must identify and genuinely weigh the reliance interests”
- “identify which specific burdens are not already addressed by existing exceptions”
- “quantify those burdens on the record rather than assert them”

What it names

National Forests: Carson 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 The Roadless Area Conservation Rule has protected places that matter to real people doing real work, and rescinding it would be a mistake this country will spend decades undoing. I worked for the Forest Service at Carson National Forest and saw firsthand how valuable roadless areas are to both the people and the businesses around them. The roadless areas near Sipapu Ski Resort meant available clean water, less fire risk, and they did not prevent the continued expansion of the resort. Visitors, residents, and snow-making operations all depended on that water. Having lived in northern New Mexico, I know that water is scarce and hard-won. Entire towns understand that without the water quality protection roadless areas provide, the town itself is at risk. New Mexico holds 120 inventoried roadless areas totaling 1,505,508 acres, and across the Southwestern region 739 municipal water intakes sit in watersheds containing affected roadless areas. The stakes for communities here are not abstract. On wildfire, I have watched what roads actually do. I've had to leave many areas due to roadside fires started. I was also living in Taos when the Calf Canyon Fire started, and I returned to work on Carson National Forest right after it. While that fire started from a different cause, what I witnessed was a difficult recovery paired with hard discussions about past Forest Service mismanagement that increased fire risk. One thing became clear in those conversations about past local fires: roads increase fire risk because they increase human activity. The agency's own record 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." The current rule already allows roads for firefighting. Repealing it and permitting additional traffic and logging will increase ignition risk to the communities nearby. I ask that the agency explain why this proposal departs from its own prior findings on fire occurrence, and that it reconcile the rescission with the ignition data in its own DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The financial case for rescission does not hold together either. There is already a shortage of funds to manage existing roads. Creating new ones is a mismanagement of funds, and it makes zero sense financially, safety-wise, or as a long-term investment in the economy and health of these forests. The agency's own record acknowledges 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 must reconcile this proposal with its own economic 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 it must explain on the record how an action whose own Cost Benefit Analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog. The agency also has not explained what specific permitting or administrative burdens the rule actually creates that cannot already be addressed under its own exceptions. The rule as written "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 agency should identify which specific burdens are not already addressed by existing exceptions, including those for public health and safety, existing mineral leases, and community wildfire protection, and it should quantify those burdens on the record rather than assert them. Finally, this comment is itself a reliance interest. My work on Carson National Forest, my understanding of what these areas protect, and the communities I have seen depend on clean water and reduced fire risk all rest on the continued operation of the rule. The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. The agency must identify and genuinely weigh the reliance interests described in the comments it receives, including this one, before it proceeds any further. Keep the rule in place and keep protecting the people nearby. Sincerely, A concerned citizen