Comment Analysis · Docket FS-2025-0001

FS-2025-0001-260081

Opposes rescissionA2 moderateSubstance 11/24Owed an answerPosted August 23, 2026 On Regulations.gov

In short: The comment establishes that the agency's proposed rescission of the Roadless Area Conservation Rule conflicts with its own record data regarding fire density on roaded lands, fails to justify the economic net benefit given a $6.9 billion maintenance backlog, and violates NEPA by predetermining the outcome through a deregulatory purpose that dismissed protective alternatives.

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
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “fire density is higher on roaded land than inside the affected roadless areas”
- “opening those areas to roads in the name of fire management... is not a solution”
Governance Policy Process
- “predetermined the outcome of its NEPA review”
- “policy preference dressed as environmental review”
- “analyze at least one fully protective alternative before this proceeding can satisfy NEPA”
Economic Impact Fiscal
- “net present value ranging from -$92 million to +$199 million”
- “agency is already $6.9 billion behind on maintaining the roads it has”
- “recreation losses of at least $6.1 million a year”
Water Quality Quantity
- “1,034 municipal water intakes sitting in watersheds containing affected roadless areas”
- “deserve more than a cost-benefit analysis that cannot confirm a net benefit”

What it names

National Forests: Six Rivers National Forest

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 The beauty of California's wildlands is worth protecting, and Six Rivers National Forest is part of what I love about this state. I am filing this comment in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001) because the proposal conflicts with the agency's own record, its own numbers, and any reasonable standard of responsible public land management. The agency has justified this rescission partly on wildfire and fuels management grounds, but its own prior findings cut directly against that rationale. The agency's 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." Six Rivers sits in California, which holds 381 inventoried roadless areas totaling 4,389,760 acres. Opening those areas to roads in the name of fire management, when the agency's own data show far higher fire density on roaded land, is not a solution. 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 DEIS Table 21, which shows fire density is higher on roaded land than inside the affected roadless areas. The economic case for rescission is no stronger. The agency's own 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 those modest projected gains, the agency's own Cost Benefit Analysis projects timber revenue of $5.2 to $11.4 million a year to the Forest Service against recreation losses of at least $6.1 million a year, with a net present value ranging from -$92 million to +$199 million. That range cannot establish a net benefit. Meanwhile the agency is already $6.9 billion behind on maintaining the roads it has, against a road budget of about $73 million a year. We need to manage our public lands responsibly and maintain them for all who wish to enjoy them, and building new roads into country that has none, when the agency cannot maintain the roads it already has, is not responsible management. The agency must reconcile those numbers on the record and explain how this action is justified given a maintenance backlog of that size. On alternatives, the agency's stated purpose of deregulation predetermined the outcome of its NEPA review. Every conservation-oriented alternative was dismissed not because forest conditions required it but because the purpose was written to foreclose protection. The agency dismissed alternatives offering more protection as unresponsive to deregulatory executive orders, and it eliminated the option of keeping existing boundaries because it "would continue to restrict local decision-making discretion" and because analyzing roadless values is described as "an administrative and legal burden for the agency." That is not a forest-condition rationale. It is a policy preference dressed as environmental review. The agency must restate its purpose and need in terms of actual forest conditions and analyze at least one fully protective alternative before this proceeding can satisfy NEPA. Finally, even accepting the fire rationale at face value, the agency's own record states that the purpose and need is to reduce regulatory burden and return decisionmaking to local officials, not to address wildfire, and that the benefits of added fuel-management access "would likely be modest and localized." The agency itself identified that overlap with the wildland-urban interface as defined by HFRA is 9.8 million acres, 24 percent of the affected area. It built a WUI-targeted alternative that would address fire risk where it is most acute, and then rejected it in favor of nationwide rescission. Why? That question has not been answered. I want an answer in this record before any final decision is made. Public land in California, including the 1,034 municipal water intakes sitting in watersheds containing affected roadless areas across the Pacific Southwest region, and the roadless acres I value for wildlife and recreation, deserve more than a cost-benefit analysis that cannot confirm a net benefit and a purpose statement that treats legal protection as a burden. I urge the agency to withdraw this proposal. Lastly, as a young person myself, I hope the future generations are able to experience the wonders of Six Rivers National Forest. Sincerely, Nikka G. Los Angeles, CA