Comment Analysis · Docket FS-2025-0001

FS-2025-0001-597624

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

In short: The comment documents that the agency's DEIS contains internal contradictions regarding wildfire risk and ungulate survival, and fails to apply cited fragmentation data to the 40.1 million acres of affected land, while the commenter asserts standing based on recreational use of the Red Feather Lakes area.

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
- “diverse animal life in these landscapes depend on unroaded habitat”
- “elk survival rates increased during a road closure”
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
- “protect big game habitat, fisheries, and wildlife connectivity”
Recreation Tourism Public Use
- “maintain my mental, physical, and spiritual health”
- “quiet of those unroaded landscapes”
- “Watching owls, hawks, squirrels, foxes, pikas, and bighorn sheep”
Forest Management Wildfire
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “policy that multiplies road access serves fire risk reduction”
- “reconcile the rescission with the ignition data in its own DEIS Table 21”
Governance Policy Process
- “administrative burden argument fares no better”
- “agency has not shown what burdens remain that rescission alone could address”
- “agency must apply the cited fragmentation range to the 40.1 million potentially affected acres”

What it names

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 gapEvidenceRequestAlternativeLegal

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I oppose rescinding or altering the 2001 Roadless Rule and support Alternative 1, the No Action alternative. The roadless areas near Red Feather Lakes are where I go to maintain my mental, physical, and spiritual health. Watching owls, hawks, squirrels, foxes, pikas, and bighorn sheep is an essential part of my life as a Coloradoan, and the quiet of those unroaded landscapes is what makes that possible. I am filing this comment in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule under Docket FS-2025-0001. The agency's own record undercuts the wildfire rationale it offers for this rescission. 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." That finding sits in the same document that proposes to open 40.1 million acres to road construction. The agency offers no explanation for how a policy that multiplies road access serves fire risk reduction. 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 its own DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The administrative burden argument fares no better when measured against what the rule actually says. The DEIS acknowledges that the rule "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 already permit road construction for public health and safety, for existing mineral leases, and for community wildfire protection, the agency has not shown what burdens remain that rescission alone could address. I ask that the agency identify, specifically and on the record, which burdens are not already resolved by those exceptions, and that it quantify them. The diverse animal life in these landscapes depend on unroaded habitat, and the DEIS contains evidence directly relevant to their survival that the agency declines to apply. The document cites the finding that "elk survival rates increased during a road closure and decreased when the gates were removed (Cole 1997), and that elk avoid roads and select unroaded habitat." The agency produced that citation and then projected no population-level effects on big game anywhere in the document. The same record that tells us what roads do to ungulate survival stops short of asking what opening 40.1 million acres would do to ungulate populations or to hunting opportunity. I ask that the agency project those effects on big game populations and hunter opportunity before any final decision is made. The fragmentation data receive the same partial treatment. The DEIS cites the finding that "habitat fragmentation reduces biodiversity by 13 to 75 percent." That range is wide, the stakes are measurable, and the affected area is known. Strikingly, no projection of that range across the 40.1 million acres of potentially affected environment appears anywhere in the analysis. The agency built Alternative 3 specifically because commenters asked it to protect big game habitat, fisheries, and wildlife connectivity, and then selected the alternative that protects none of it. The cited fragmentation finding demands application at the scale of this decision. The agency must apply the cited fragmentation range to the 40.1 million potentially affected acres before this proceeding closes. I believe public lands must be managed with communities, especially those most affected, including tribal councils and indigenous individuals. The record before me does not reflect that standard. The agency identified the harms, noted the alternatives, and chose the path its own data argue against. I ask that it answer, specifically, each of the questions raised above. Sincerely, Zoë Roberts, Fort Collins, CO