Comment Analysis · Docket FS-2025-0001

FS-2025-0001-258951

Opposes rescissionA3 weakSubstance 9/24Owed an answerPosted August 23, 2026 On Regulations.gov

In short: The comment documents that road construction in the Bear Mountain area of the Los Padres National Forest and Big Sur watersheds would increase wildfire ignition density and cause erosion, citing specific peer-reviewed studies and economic data to oppose the rescission of the Roadless 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

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

Water Quality Quantity
- “harm the beautiful watersheds of Big Sur”
- “erode onto Hwy 1”
- “disrupting our local natural resources”
Forest Management Wildfire
- “Bringing more roads will cause more fires”
- “Road-building will absolutely increase fire risk”
- “wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads”
Environmental Protection Biodiversity
- “harm our beautiful natural ecosystems”
- “roadless tracts bolster habitat representation and landscape connectivity”
- “conserve threatened & endangered species”
Scientific Research Evidence
- “peer-reviewed science shows the opposite”
- “A 2026 study in Fire Ecology by Aplet, Hartger & Dietz”
- “Balch et al., PNAS 2017”

What it names

National Forests: Los Padres National Forest
Roadless areas: Bear MountainSanta Cruz
Works cited: 10.1016/j.apgeog.2011.09.004

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapLegal

Brooke L. Rollins and Tom Schultz, Living next to these forests, I know where the water comes from. Introducing miles of road will inevitably and irrevocably harm the beautiful watersheds of Big Sur, and erode onto Hwy 1- already strained by landslides and harsh winter rains. I work for the Santa Cruz RCD and have made it my career to engage people around Forest Health and Community Resilience. Morr roads does nothing but exploit our wild lands to serve corporate greed while threatening the communities close to them. One occasion in particular illustrates what that relationship means in practice. The Timber Fire is currently burning through Big Sur, an area that historically had regular fire intervals that maintained the chapparal we all love along the coast. Bringing more roads will cause more fires and disrupt the regularity of the fire interval, potentially lead to type conversion, and cause catastrophic environmental change in an area many locals look to to appreciate the public lands of our great nation. What the preceding account reflects is not sentiment alone but a record of sustained public use and dependence that the Department is obligated to weigh in this proceeding. Regarding the Bear Mountain in the Los Padres National Forest, California: Road building and vegetation management reshape fire regimes by changing ignition sources, fuel loads, and landscape-scale fire behavior. Rescinding the Roadless Rule would open the Bear Mountain, Los Padres National Forest to road construction and associated ground disturbance. Road-building will absolutely increase fire risk and harm our beautiful natural ecosystems. This area is essential to the community and repeated devastating wildfire caused by human ignition will exponentially threaten and change the lands we love- eventually causing major erosion and disrupting our local natural resources and economy. Building more roads in national forests would be a drain on taxpayers. Even with the Roadless Rule in place, the Forest Service already has a 380,000-mile road system—twice as long as the U.S. highway system—crisscrossing national forests. The agency cannot afford to maintain it: the deferred-maintenance road backlog was estimated at $8.4 billion in the 2001 Final Environmental Impact Statement and is roughly $15.6 billion in today's dollars. Although proponents of rolling back the Roadless Rule claim it is needed for wildfire management, the peer-reviewed science shows the opposite. A 2026 study in Fire Ecology by Aplet, Hartger & Dietz analyzed 32 years of wildfire data across all eight contiguous-U.S. Forest Service regions and found wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads, compared to just 1.97 fires per 1,000 hectares in inventoried roadless areas—a fourfold difference. A separate national analysis (Balch et al., PNAS 2017) found that 84% of all U.S. wildfires are human-caused. Roads are the primary vector for human ignitions, so building roads into roadless areas is likely to result in more fires, not fewer. Most ignitions near roads are human-caused. The same study found that human-caused ignitions were concentrated near roads, near the wildland-urban interface, and in high-road-density areas. Lightning-caused ignitions, by contrast, were concentrated away from roads and in lower-density areas. The further from a road, the fewer human-caused fires (Narayanaraj & Wimberly 2012; Aplet et al. 2026). — Ganapathy Narayanaraj | Michael C. Wimberly, 2012 · Applied Geography (https://doi.org/10.1016/j.apgeog.2011.09.004) “Klamath-Siskiyou case study mapped ~500 roadless areas and found roadless tracts bolster habitat representation and landscape connectivity, including smaller roadless patches. — Research - Biodiversity Conservation” “National-scale analysis found 77% of roadless areas have potential to conserve threatened & endangered species, with strong concordance with grizzly recovery zones.” “Analysis of 32 years of wildfire data across all eight contiguous-U.S. Forest Service regions found wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads versus just 1.97 fires per 1,000 hectares in inventoried roadless areas—a fourfold difference. Ignition density decreased steadily as distance from roads increased, irrespective of designation. The study concludes that "building roads into roadless areas is likely to result in more fires." — Research - Fire Safety” “Finds Tongass & Chugach forests hold a disproportionate share of tree carbon in high-integrity landscapes among U.S. national forests—critical for meeting climate and biodiversity goals. — Research - Carbon Storage” The grounds articulated in this comment support one conclusion: the Roadless Area Conservation Rule should not be rescinded. CommentID: RLC-20260823-4E6CHL