Comment Analysis · Docket FS-2025-0001

FS-2025-0001-259912

Opposes rescissionA2 moderateSubstance 16/24Owed an answerPosted August 23, 2026 On Regulations.gov

In short: The comment establishes that the agency's own DEIS data and Cost Benefit Analysis contradict the proposal's wildfire and economic justifications, and documents a specific reliance interest in the 2001 Roadless Area Conservation Rule based on the commenter's use of the Black Mountain roadless area.

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

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”
- “roaded land burning at dramatically higher rates”
- “reconcile that finding with every claim in the preamble that road access would improve fire outcomes”
Recreation Tourism Public Use
- “I camp and hike near Logger Flats, and I photograph landscapes and wildflowers”
- “recreation losses of at least $6.1 million a year”
- “I photograph the landscapes and wildflowers of these areas because they are intact”
- “recreation value bound up in that intactness is real”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “net present value range spanning negative $92 million to positive $199 million”
- “existing road system already carries a $6.9 billion maintenance backlog”
- “A range that wide cannot establish a net benefit”
Governance Policy Process
- “The agency must explain, clearly and with reference to its own ignition data”
- “An agency changing a policy of that duration and that reach is required to identify and weigh the reliance interests”
- “The Cost Benefit Analysis weighs none”
- “I ask that the agency do exactly that”

What it names

National Forests: Sequoia National Forest
Roadless areas: Black Mountain

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I camp and hike near Logger Flats, and I photograph landscapes and wildflowers in the Black Mountain roadless area in Sequoia National Forest. I have been there. I want it protected, and I am filing this comment to oppose the rescission of the 2001 Roadless Area Conservation Rule. The agency's own record makes the wildfire rationale for this proposal very difficult to understand. The DEIS states plainly: "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." Black Mountain sits within California, which holds 381 inventoried roadless areas totaling 4,389,760 acres, many of them in fire-prone landscapes where the agency's own data show roaded land burning at dramatically higher rates. The proposal nonetheless invokes fuels management as a justification for opening these areas to road construction. The agency must explain, clearly and with reference to its own ignition data in DEIS Table 21, why the rescission is consistent with the finding embedded in its own environmental review, and it must reconcile that finding with every claim in the preamble that road access would improve fire outcomes. The economic case is no stronger. The record contains this acknowledgment from the agency itself: "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 marginal extractive gain, the Cost Benefit Analysis the agency placed in the record projects timber revenue to the Forest Service of $5.2 to $11.4 million a year, recreation losses of at least $6.1 million a year, and a net present value range spanning negative $92 million to positive $199 million. A range that wide cannot establish a net benefit, yet the proposal moves forward while the existing road system already carries a $6.9 billion maintenance backlog. I photograph the landscapes and wildflowers of these areas because they are intact; the recreation value bound up in that intactness is real, and the agency's own numbers reflect it. The agency must square this analysis with its stated rationale, and explain how a proposal whose own Cost Benefit Analysis is this uncertain justifies further expanding a road network the agency already cannot afford to maintain. Finally, the proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. This comment is one such interest. I have been to Black Mountain. I go there to photograph wildflowers and landscapes that exist as they do because the rule has held for more than two decades. An agency changing a policy of that duration and that reach is required to identify and weigh the reliance interests its prior rule created. I ask that the agency do exactly that, beginning with the comments it is receiving now, including this one. Sincerely, Jack Cairl Los Angeles, CA