Comment Analysis · Docket FS-2025-0001

FS-2025-0001-602709

Opposes rescissionA2 moderateSubstance 16/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment places on the record a request for the agency to reconcile its economic analysis regarding timber revenue versus recreation losses and road maintenance backlogs, and to analyze an alternative retaining 2001 Roadless Rule protections for the Indian Peaks and Superior National Forest watersheds.

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

A2 moderate: Hard to dismiss — it shows cause and effect.

Owed an answer on Analytical gap, Evidence.

Standard dismissals it defeats

  • 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.

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.
  • 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.
  • 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.
  • 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.

Topics

  • Recreation Tourism Public Use
    • “fishing and hiking are excellent”
    • “hiking and camping in the Indian Peaks adjacent area”
    • “canoe trip with my friend and my goddaughter”
    • “recreation losses of at least $6.1 million a year”
  • Water Quality Quantity
    • “preserve the pristine cleanliness of the watershed”
    • “tragedy to put roads in such proximity to the watershed”
    • “maintain the wilderness, the pure watershed”
  • Wildlife Habitat
    • “observed loons and a bald eagle”
    • “fed birds and rodents in the wilderness”
    • “maintain the... bird habitat”
    • “habitat for biodiversity”
  • Climate Carbon Storage
    • “keeping additional carbon out of the atmosphere”
    • “protecting ecosystems with large trees for their carbon stores”
    • “resilience to drought and fire”

What it names

National Forests
Superior National Forest
Roadless areas
Blue Lake

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceLegal

I have been visiting the Indian Peaks and the Indian Peaks Adjacent Area since I moved to Boulder, CO, in 2005. The fishing and hiking are excellent, and some of my most blessed moments have come while watching the evening light over Blue Lake. The baby moose I discovered in 2013 changed my relationship with my partner. I will be hiking and camping in the Indian Peaks adjacent area for the rest of my life. I ask that the agency explicitly describe its plan for how to preserve the pristine cleanliness of the watershed in Colorado. Superior National Forest is one of the most magical places in the upper Midwest of the United States. So much of the land in neighboring North Dakota has already been privatized and developed. It will be a tragedy to put roads in such proximity to the watershed of the Boundary Waters. I have canoed and backpacked in the forest with my best friend, where I observed loons and a bald eagle. When we hiked in 2008, we encountered a great deal of blown-down timber from a past tornado in the area. This resulted in carpets of fresh raspberries that fed birds and rodents in the wilderness. I will be returning in the summer of 2028 for a canoe trip with my friend and my goddaughter. Please keep protections in place for all parts of wilderness preserved by the Roadless Rule. Losing the wild nature of this area will condemn us to consumerist doom. I ask the agency to explicitly describe what steps it will take to maintain the wilderness, the pure watershed, and the bird habitat in the Superior National Forest. "The visitor industry is the largest private sector contributor to regional employment after government. The visitor industry provides over 8,000 jobs, 18 percent of regional employment, and over $249 million in earnings, 11 percent of regional earnings, each year." (Complaint para. 51, same filing, pp. 22-23 of 50) "Given the urgency of keeping additional carbon out of the atmosphere and continuing carbon accumulation from the atmosphere to protect the climate system, it would be prudent to continue protecting ecosystems with large trees for their carbon stores, and also for their co-benefits of habitat for biodiversity, resilience to drought and fire, and microclimate buffering under future climate extremes." (Mildrexler, Berner, Law, Birdsey and Moomaw 2020, Front. For. Glob. Change 3:594274, abstract) I ask that the agency reconcile the proposal with its own economic analysis, which projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million, and that it 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. I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule's protections for the areas named above. Where this proposal rests on factual conclusions that differ from the agency's own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record. Sincerely, Michael Edward Christoph Denver, Colorado

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