Comment Analysis · Docket FS-2025-0001

FS-2025-0001-589216

Opposes rescissionA1 strongSubstance 16/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment establishes that the agency's DEIS contains internal contradictions regarding wildfire risk and wildlife impacts, cites specific data (Table 21, CBA figures) showing a lack of net economic benefit, and documents the commenter's direct use of specific roadless areas in New Mexico (Pecos, Rio Medio) as a basis for standing.

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
- “Birds, deer, fox, coyotes: these are not abstractions for them”
- “bird richness declines with road presence in forested habitat”
- “roads built for oil extraction may have altered mule deer migration routes”
- “deer population recovery by preserving old-growth winter shelter”
Water Quality Quantity
- “losing it would impact the watershed”
- “They are the water supply”
- “739 municipal water intakes sit in watersheds containing affected roadless areas”
Forest Management Wildfire
- “Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “reconcile the rescission with the ignition data in its own DEIS Table 21”
Legal Regulatory Framework
- “The Tenth Circuit already reviewed that question and held that the 2001 rule was within the authority Congress granted”
- “The agency must address that holding, including the court's conclusions regarding the Organic Act”
- “That approach was litigated and lost”

What it names

National Forests: Carson National Forest Santa Fe National Forest
Roadless areas: Rio Medio
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 children I work with in my forest school program are under eight years old. What I bring them to, every time, is the national forest near where I live. Birds, deer, fox, coyotes: these are not abstractions for them. They are the lesson. When this administration proposes to rescind the 2001 Roadless Area Conservation Rule entirely, it is proposing to dismantle the protection that makes that lesson possible. I have backpacked in the Pecos, in the Carson National Forest, for over a decade and a half. Losing that would be painful. That is the only word I have for it, and I think it is the right one. Rio Medio, in the Santa Fe National Forest, is so incredibly special, and losing it would impact the watershed. New Mexico holds 120 inventoried roadless areas totaling 1,505,508 acres. These are not marginal scraps. They are the water supply and the wildlife corridor and the quiet that makes birds findable and children teachable. On fire, the agency's own record undermines its own justification. The DEIS states directly: "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 proposal cites fuels management as a rationale for rescission. Those two positions cannot both be true. I ask the agency to explain the departure from its own prior findings and to 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 birds I look for with children in these forests depend on exactly the conditions the rule protects. The DEIS cites findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. For deer, the agency's own record cites research finding that roads built for oil extraction may have altered mule deer migration routes and increased their movement speed, and the Tribal Summary Impact Statement credits the rule's protection with deer population recovery by preserving old-growth winter shelter. These are not outside critiques. These are the agency's own citations. I want to know how the agency squares opening these areas to roads with its own documented findings on the wildlife consequences of doing so. The economic case for rescission does not hold up either. The 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 agency's own Cost Benefit Analysis 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 negative $92 million to positive $199 million. Across the Southwestern region alone, which includes New Mexico, 739 municipal water intakes sit in watersheds containing affected roadless areas. The agency must reconcile this proposal with an analysis that cannot establish a net benefit, and explain how it justifies expanding a road system already carrying a $6.9 billion maintenance backlog. On the state-by-state approach the proposal advances: the record itself records the agency's prior rejection of the rule's approach in favor of local flexibility, citing "its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." That approach was litigated and lost. The agency must address its own prior finding that local decision-making can incrementally reduce nationally significant roadless values, and explain how this proposal avoids the deficiencies identified the last time the national rule was replaced with a state-by-state system. Finally, on statutory authority: the Tenth Circuit already reviewed that question and held that the 2001 rule was within the authority Congress granted. The court stated: "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 must address that holding, including the court's conclusions regarding the Organic Act and the Multiple-Use Sustained-Yield Act, and explain the basis for any contrary legal position. I oppose this rescission. The places it would open are the places I work in and love. The agency's own record does not support this action. Sincerely, Resident of Santa Fe, NM