Comment Analysis · Docket FS-2025-0001

FS-2025-0001-613203

Opposes rescissionA2 moderateSubstance 14/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents specific deficiencies in the agency's analysis regarding water quality, wildfire risk, economic net benefits, and wildlife habitat impacts, citing internal record contradictions and requesting reconciliation of these gaps before finalizing the rescission of the 2001 Roadless Area Conservation Rule.

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

Water Quality Quantity
- “739 municipal water intakes across the Southwestern region sit in watersheds containing affected roadless areas”
- “does not adequately account for what road construction would do to the water those communities and that country depend on”
- “address that gap directly”
Forest Management Wildfire
- “Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “reconcile the rescission with the ignition data in DEIS Table 21”
Wildlife Habitat
- “elk survival rates increased during a road closure and decreased when the gates were removed”
- “elk avoid roads and select unroaded habitat”
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “recreation losses of at least $6.1 million a year”
- “Forest Service is already carrying a $6.9 billion road maintenance backlog”

What it names

National Forests: Carson National Forest

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The backcountry is where I harvest food for my family, teach my children the skills they need, and remind them that the natural world exists beyond screens. Bikepacking has shown me how far roadless country extends and how quickly a road can shrink it. The Pecos area in Carson National Forest, New Mexico, is a gem, and something that needs to be preserved for future generations. I oppose the rescission of the 2001 Roadless Area Conservation Rule and ask the agency to address the specific failures in its analysis described below. New Mexico holds 120 inventoried roadless areas totaling 1,505,508 acres. The Pecos alone accounts for 13,436 of them. When I take my children into that country and go off trail to find food, I am depending on the character that roadless designation protects. The agency's own record acknowledges that 739 municipal water intakes across the Southwestern region sit in watersheds containing affected roadless areas. The proposal does not adequately account for what road construction would do to the water those communities and that country depend on, and I expect the agency to address that gap directly. The wildfire rationale offered for rescission is the one I find hardest to square with what the agency itself has written. The record 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 is the agency's own language, cited in support of the protection this rule provides. The proposal now treats road access as a tool for reducing fire risk, but the agency's prior findings point in the opposite direction. I ask that the agency explain why the current proposal departs from those findings and reconcile the rescission with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic case is similarly difficult to follow. The agency's record acknowledges that "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." Against that baseline, the agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service, set against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. The Forest Service is already carrying a $6.9 billion road maintenance backlog. How does an action whose own analysis cannot establish a net benefit justify expanding a road system that already cannot be maintained? The agency must answer that question with specificity before this proposal moves forward. When I hunt off trail, the quality of the habitat determines everything. The agency's record is candid about what roads do to the animals I pursue: "The DEIS 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." That finding is in the record. What is not in the record is any projection of what rescission would mean for elk populations or for the hunter opportunity that depends on them. The agency should provide that projection before reaching a final decision. The fragmentation data present the same problem at a larger scale. The agency's record states: "The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent." That range is cited and then left suspended. No projection applies it to the 40.1 million acres of potentially affected environment. A cited finding that spans 13 to 75 percent is not a minor uncertainty. The agency must apply that range to the full extent of the affected environment and show what it means in practice, not simply note the number and move on. The Pecos is the kind of place that does not come back once it is roaded. I ask the agency to respond to each of the deficiencies identified here before finalizing any action that would rescind the protections the 2001 rule provides. Sincerely, Jesse Woosley Santa Fe, NM