Comment Analysis · Docket FS-2025-0001

FS-2025-0001-605557

Opposes rescissionA3 weakSubstance 8/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents that the EIS lacks specific case evidence for the rule rescission, fails to account for increased human-caused wildfire risks and non-commodity economic values on pages 216 and 225, and cites data showing insufficient funding for road maintenance relative to needs.

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

A3 weak: Substantive, but easier to set aside.

Owed an answer on 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.
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.
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.
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

Forest Management Wildfire
- “Construction of additional roads in roadless areas will not decrease wildfires”
- “increased road access the opportunity for wildfires will increase”
- “The Forest Service does not have sufficient resources to maintain their existing road network”
Governance Policy Process
- “The intent of this rulemaking therefore is reflective of a political aspiration or ideology”
- “the entire basis of the rule is unsupported by a real need”
- “return land management decision-making for inventoried roadless areas to local Forest Service officials”
Economic Impact Fiscal
- “The economic impact of recreation is on a par with the expected increase in timber sales”
- “Repealing the roadless rule would disproportionately impact these citizens in favor of especially timber interests”
- “non-commoodity values listed on pages 216 and 225 are not represented in economic calculations”
Recreation Tourism Public Use
- “diminshment of recreational opportunities”
- “major component of local economies and small businesses”
- “poorer air and water quality”

What it names

National Forests: Santa Fe National Forest

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeEA analysisAnalytical gapEvidenceRequest

I am opposed to the USDA revocation of the roadless rule. On page 10 of the EIS you state: “The Department is proposing this rule rescission to reduce regulatory burden and return land management decision-making for inventoried roadless areas to local Forest Service officials. Subsequent text continues in the same vein. The remainder of the EIS does not present any specific case evidence that there is a need for these actions. The intent of this rulemaking therefore is reflective of a political aspiration or ideology. Thus the entire basis of the rule is unsupported by a real need and the revocation should be rejected. Construction of additional roads in roadless areas will not decrease wildfires. Wildfires are caused by past management practices, extreme temperature, fuel buildup, nightime temperatures, wind, and the ability to respond to fires, which has been severely curtailed by the current administration, specifically within the Forest Service. “With increased road access, initial attack success rates would be expected to increase. Additional roads would provide safer, more effective, and more efficient containment opportunities, potentially reducing fire sizes and durations. Page 103. Not mentioned is that increased road access the opportunity for wildfires will increase as it will make the roadless areas more open to human activity. Scientific American states that the majority of wildfires that threaten communities are started by human activities. Of major concern in fire fighting is the reduction in numbers of federal firefighters. The ability of firefighters to respond to fires is a key component in minimizing impacts. Where hiring rebounded from the administration cuts of 2025, it was in non-permanent employees, thus a lack of long-term readiness (https://www.federalhiringdata.com/articles/wildland-firefighter-workforce-2026). The Forest Service does not have sufficient resources to maintain their existing road network. The EIS states that annual maintenance need for Forest Service roads is 1.6 billion and their appropriation was 270 million in 2023. I personally experienced the very poor quality of passenger car roads in the Santa Fe National Forest, where turning back was the only option. Creating more roads when the existing roads cannot be maintained is a unsupportable policy. The economic impact of recreation is on a par with the expected increase in timber sales and is a major component of local economies and small businesses. Repealing the roadless rule would disproportionately impact these citizens in favor of especially timber interests. Further the non-commoodity values listed on pages 216 and 225 are not represented in economic calculations. These impacts have an economic impact (i.e. poorer air and water quality) and the diminshment of recreational opportunities for example. This disregard is one more reason I oppose the revocation of the roadless rule.