Comment Analysis · Docket FS-2025-0001

FS-2025-0001-280738

Opposes rescissionA2 moderateSubstance 16/24Owed an answerPosted August 28, 2026 On Regulations.gov

In short: The comment documents that the agency failed to reconcile its own DEIS findings on bird abundance and fire ignition rates with the proposal, did not quantify fire frequency impacts from new road access, and issued a flawed regulatory flexibility certification that ignored specific economic losses to small entities in the Kaibab National Forest.

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

Wildlife Habitat
- “varied plant-life and birds I found”
- “bird richness declines with road presence”
- “road-noise experiments in a roadless area cut bird abundance”
- “birds that made those mornings memorable face exactly the pressures”
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 ignitions increase in abundance with proximity to roads”
- “weighed that expected increase against whatever wildfire hazard reduction it claims to achieve”
Recreation Tourism Public Use
- “That quiet beauty is what I am writing to defend”
- “lost recreation benefit at a minimum of $6.1 million a year”
- “outfitters, guides, and tour operators actually holding permits”
- “hoping to find the same quiet mornings I found there”
Legal Regulatory Framework
- “regulatory flexibility analysis reaches a no-significant-impact conclusion”
- “The proposed rule certifies no significant impact on small entities”
- “solicits any reliance interests in the current rule”
- “The agency must identify and weigh the reliance interests”

What it names

National Forests: Kaibab National Forest
Roadless areas: Coconino Rim

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Coconino Rim is where I woke up to birdsong and watched sunlight rain down through the trees. I ran the trails that crossed the forest there in 2018, and I was pleased and surprised by the varied plant-life and birds I found. That quiet beauty is what I am writing to defend. I oppose the rescission of the 2001 Roadless Area Conservation Rule and ask the agency to answer the specific questions below. The Coconino Rim covers 7,213 acres in the Kaibab National Forest in Arizona. The birds I encountered there are precisely the kind of wildlife the agency's own record shows roadless protection serves. The DEIS cites findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. If roads are opened into the Coconino Rim, the birds that made those mornings memorable face exactly the pressures the agency's own science describes. I ask the agency to explain what weight it gave these findings when evaluating the biological consequences of rescission for inventoried roadless areas like this one. The agency frames part of this proposal around wildfire and fuels management. Its 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 agency has not reconciled that finding with the direction this proposal takes. I ask that the agency explain, in its response, why the proposal departs from these prior findings and how it accounts for the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. That ignition data deserves its own attention. The DEIS states that human-caused ignitions increase in abundance with proximity to roads. The agency has not quantified what new road access in currently protected areas would mean for fire frequency, nor has it weighed that expected increase against whatever wildfire hazard reduction it claims to achieve. The agency should provide that quantification and that weighing before any final action is taken. Arizona holds 78 inventoried roadless areas totaling 1,174,256 acres, and across the Southwestern region, which includes Arizona, 739 municipal water intakes sit in watersheds containing affected roadless areas. The proposal's regulatory flexibility analysis reaches a no-significant-impact conclusion by spreading losses across every small firm in the relevant sector nationally, rather than assessing the outfitters, guides, and tour operators actually holding permits in places like the Kaibab. The agency's own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year and concedes some firms may lose those receipts entirely. 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. That certification cannot stand alongside the analysis that accompanies it. The agency should withdraw it and assess the impact on the small entities actually operating in the potentially affected roadless areas. The proposal itself invites comment on reliance, stating it 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 visit to the Coconino Rim and every plan I and others form around the continued protection of places like it represent exactly the kind of reliance interest the agency has invited but not assessed. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before it proceeds. Protect the Coconino Rim and Arizona's other roadless areas for the people who will come after me hoping to find the same quiet mornings I found there. Sincerely, Laurie N Lakewood, CO