Comment Analysis · Docket FS-2025-0001

FS-2025-0001-607026

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

In short: The comment establishes that the proposed rescission of the Roadless Area Conservation Rule is procedurally deficient due to a compressed comment window without public meetings, and factually unsupported regarding wildfire risk and fiscal capacity, specifically citing that wildfires are four times more likely to start near roads and that the Forest Service lacks the budget for a multi-billion dollar road maintenance backlog.

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 Analytical gap.

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

Governance Policy Process
- “not consistent with the kind of transparent, deliberate process”
- “compressed comment window with no public meetings”
- “one of the most extensive public engagement processes in Forest Service history”
Water Quality Quantity
- “supply drinking water to communities across the Southwest”
- “watershed protection”
Wildlife Habitat
- “provide critical wildlife habitat”
- “protected America's last wild national forest landscapes”
Cultural Heritage Indigenous
- “hold tribal cultural resources of deep and lasting significance”

Attachments

1 file. Counts as 2 — Counted from the files: The enclosed submissions were counted from the files themselves.

Enclosed submissions

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeAnalytical gapEvidenceRequest

New Mexico Wild is pleased to transmit the following public comments in strong opposition to the proposed rescission of the Roadless Area Conservation Rule. This document compiles 1,179 individual comments collected from September 26–October 6, 2026. The Roadless Area Conservation Rule has protected America's last wild national forest landscapes for 25 years, established through one of the most extensive public engagement processes in Forest Service history — 600 public meetings and 1.6 million public comments — reflecting broad, enduring public support for keeping these lands free from industrial logging and permanent road construction. Rescinding it now, in a compressed comment window with no public meetings, is not consistent with the kind of transparent, deliberate process these lands and communities across the country deserve. The commenters represented here come from across New Mexico and the country, and they understand what is at stake. New Mexico's roadless forests supply drinking water to communities across the Southwest, provide critical wildlife habitat, hold tribal cultural resources of deep and lasting significance, and anchor an outdoor recreation economy that supports jobs and livelihoods across the region. Once roads are built and lands are opened to extraction, these values cannot be recovered. The wildfire justification for rescission is not supported by federal data. The Roadless Rule already explicitly permits suppression, restoration, thinning, and fuel reduction activities. In fact, wildfires are approximately four times as likely to start near roads than within roadless areas — rescinding the Rule would worsen, not improve, fire outcomes. Rescission also makes no fiscal sense: the Forest Service already carries a multi-billion dollar road maintenance backlog it lacks the budget to address. Taxpayers should not be asked to fund new roads the agency cannot maintain. New Mexico Wild urges the Forest Service to retain the Roadless Area Conservation Rule in its entirety and reject any proposal to rescind or weaken protections for New Mexico's 1.6 million acres of Inventoried Roadless Areas or the 45 million acres protected nationally. Each letter that follows reflects the individual voice of a concerned community member. We ask that each comment be entered into the official record. Respectfully submitted, New Mexico Wild