Comment Analysis · Docket FS-2025-0001

FS-2025-0001-606507

Opposes rescissionA1 strongSubstance 14/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents that the agency's proposal to rescind the Roadless Area Conservation Rule contradicts its own prior findings on wildfire incidence and economic data, fails to address the specific impacts on Colorado's roadless areas and 325 municipal water intakes, and requests the agency to explain these discrepancies and withdraw the proposal.

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, 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
- “325 municipal water intakes sit in watersheds containing affected roadless areas”
- “not interested in polluting my drinking water with sediment from timber logging”
- “pollutants from mining operations”
- “impossible and/or very expensive to mitigate them”
Forest Management Wildfire
- “wildfire rationale the agency offers for this proposal contradicts the agency's own record”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “roads become heavily used and the natural vegetation along them is quickly destroyed”
- “reconcile the rescission with the ignition data in its own draft environmental impact statement”
Recreation Tourism Public Use
- “protect the forests, the campgrounds, trails and natural landscapes”
- “I camp & hike in the national forests every weekend to unplug, enjoy nature”
- “threatens the things that make that possible”
- “Preserving these landscapes for our kids, grandkids, and future generations”
Economic Impact Fiscal
- “The economic case for this action is no stronger”
- “Forest Service is already $6.9 billion behind on maintaining the roads it has”
- “costs continue to outweigh the proposed revenue projected to be generated”
- “This is poor financial management”

What it names

Roadless areas: Rocky Mountain
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 placeEA analysisAnalytical gapEvidenceRequest

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I strongly oppose the rescission of the Roadless Area Conservation Rule. I’m writing to protect the forests, the campgrounds, trails and natural landscapes from being mined & logged. I camp & hike in the national forests every weekend to unplug, enjoy nature, connect with my family, and to explore our incredibly beautiful state. What the agency is now proposing to do threatens the things that make that possible, and I oppose this rescission entirely. The wildfire rationale the agency offers for this proposal contradicts the agency's own record. The administration argued opening roadless areas to new roads will improve fuel management and reduce fire risk. The agency's own prior findings state something different: "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." I have watched what forest roads bring to Colorado forests. Where there are roads, there are people, and where there are people, there are campfires and other fire risks (shooting of firearms & dirtbikes). The roads become heavily used and the natural vegetation along them is quickly destroyed. 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 draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic case for this action is no stronger. The agency's own record contains this admission: "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 Forest Service is already $6.9 billion behind on maintaining the roads it has, on a road budget of about $73 million a year. It does not make sense to build more roads when there is not enough funding to maintain the roads that already exist. Additional and unnecessary costs are the last thing the agency needs. The costs continue to outweigh the proposed revenue projected to be generated by building new roads for logging. This is poor financial management. The proposal also argues that state-specific approaches can substitute for the national rule, but the agency has been down that road. The record states that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." Colorado's roadless areas are governed by the 2012 Colorado Roadless Rule and sit outside the rescission as proposed, and the honest question the agency has not answered is what, if anything, changes in their management. Beyond Colorado, the agency must address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and must explain how this proposal avoids the deficiencies the Ninth Circuit identified the last time a national rule was replaced with a patchwork of state approaches. And the claimed permitting burden does not hold up either. The existing rule already provides for exceptions: "It 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 these exceptions, including those for existing mineral leases and community wildfire protection, and quantify them. Across the Rocky Mountain region, including Colorado, 325 municipal water intakes sit in watersheds containing affected roadless areas. We drink water that comes directly from the Rocky Mountains. I am not interested in polluting my drinking water with sediment from timber logging or pollutants from mining operations. Once those pollutants enter a drinking water supply, it is impossible and/or very expensive to mitigate them. The agency held more than 600 public meetings and took 1.6 million comments to write this rule. It has held none to undo it. National forests are what makes the United States a unique and incredible place to live. Preserving these landscapes for our kids, grandkids, and future generations is responsible stewardship. I urge the agency to withdraw this proposal.