Comment Analysis · Docket FS-2025-0001

FS-2025-0001-273036

Opposes rescissionA2 moderateSubstance 16/24Owed an answerPosted August 26, 2026 On Regulations.gov

In short: The comment documents specific deficiencies in the agency's analysis regarding sediment loading, wildfire ignition density, and small entity impacts, while asserting personal reliance interests based on repeated recreational use of the Tahoe, Umpqua, and Gifford Pinchot National Forests.

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
- “preventing sediment from leaving it via stormwater”
- “roads and their facilities can produce up to 90 percent of the sediment”
- “increase sediment in the headwaters of our drinking water”
- “roads as a source of watershed impairment”
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”
- “Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas”
- “weigh it against the claimed reduction in wildfire hazard”
Recreation Tourism Public Use
- “We go for the beauty of the forests and the spectacular mountain vistas”
- “enjoy that beauty and the wildlife that lives within these wild lands”
- “lost recreation benefit at a minimum of $6.1 million a year”
- “outfitters, guides and tour operators as affected”
Governance Policy Process
- “The regulatory flexibility analysis certifies no significant impact on small entities”
- “The agency should withdraw the certification and assess the actual operators”
- “The proposal solicits 'any reliance interests in the current rule'”
- “The agency must identify and weigh the reliance interests”

What it names

National Forests: Gifford Pinchot National Forest Tahoe National Forest Umpqua National Forest
Roadless areas: Santa Rosa

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 forests around Lake Tahoe, the Umpqua, and the Gifford Pinchot are not abstractions to me. This year my family camped in Lassen National Park and hiked in the surrounding national forest. We visit and hike in the Tahoe National Forest every year. This past summer we also explored Crater Lake National Park and the forests and waterfalls of the Umpqua National Forest. I paddle Lake Tahoe every year, and this summer I was fortunate to paddle Riffe Lake in Washington, which receives water from the Gifford Pinchot National Forest. We go for the beauty of the forests and the spectacular mountain vistas. I want my children, their children, and so on to be able to enjoy that beauty and the wildlife that lives within these wild lands. The proposal to rescind the 2001 Roadless Area Conservation Rule threatens all of that, and I oppose it. I work in environmental compliance, ensuring that the industry I work in does not pollute water. Part of that work concerns the land we farm and preventing sediment from leaving it via stormwater. The agency's own record acknowledges that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Knowing that building roads in these areas and allowing timber harvesting would increase sediment in the headwaters of our drinking water is deeply upsetting. I ask the agency to explain in this proceeding how it weighs that sediment loading against the claimed benefits of rescission, and to respond specifically to what its own analysis says about roads as a source of watershed impairment. On wildfire, the agency's own 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." The rescission is justified in part on fuels management grounds, yet those findings cut directly against opening these areas to road construction. A separate finding in the effects analysis makes the point in numbers: "Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014–2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads." The agency must quantify the expected increase in ignitions from new road access and weigh it against the claimed reduction in wildfire hazard before this rescission can proceed. The regulatory flexibility analysis certifies no significant impact on small entities. That conclusion is hard to square with what sits beside it: "The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year." Reaching a no-impact conclusion by spreading losses across every small firm in the sector nationally, rather than assessing the guides and outfitters holding permits in the affected areas, does not satisfy the purpose of that analysis. The agency should withdraw the certification and assess the actual operators working in these places. Finally, the agency itself has invited comment on reliance interests, yet its own Cost Benefit Analysis weighs none. The record states: "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." My family's repeated visits to the Tahoe National Forest, plans to visit other national parks and lands, and the expectations we carry that these places will remain intact for our children, are exactly the kind of reliance the agency invited comment on. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. Sincerely, Shannon Holbrook Santa Rosa, California