Comment Analysis · Docket FS-2025-0001

FS-2025-0001-293901

Opposes rescissionA3 weakSubstance 11/24Owed an answerPosted August 31, 2026 On Regulations.gov

In short: The comment documents the presence of the Southern Mountain Yellow-legged Frog in the Arroyo Seco IRA of the Angeles National Forest and asserts that rescinding the Roadless Rule without completing ESA Section 7 consultation violates the Endangered Species Act.

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

  • Wildlife Habitat
    • “documented occurrences of Southern Mountain Yellow-legged Frog”
    • “Roads are not built because the rule prohibits them”
    • “Habitat fragmentation strongly reduced species richness”
    • “Rescission removes that barrier and enables the full suite of habitat-altering activities”
  • Recreation Tourism Public Use
    • “public's experience of federal land is not mediated by motorized access”
    • “enjoy the outdoors as a way to disconnect from the bustle of city life”
    • “no screens and we didn't have to listen to cars zooming by”
    • “quiet, remote, and backcountry recreation values”
  • Legal Regulatory Framework
    • “triggers an independent ESA Section 7 formal consultation obligation”
    • “failure to consult is an independent basis for setting aside a federal action”
    • “unjustified departure from twenty-five years of settled policy”
    • “The Department should let the Rule stand”

What it names

National Forests
Angeles National Forest
Roadless areas
Arroyo Seco
Works cited
Haddad et al. 2015Haddad et al. 2015

The comment

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

To the U.S. Forest Service: As an outdoor enthusiast, I have observed that roadless areas on national forest lands are among the few remaining places where the public's experience of federal land is not mediated by motorized access, and I submit that the Department's proposed action has not adequately accounted for what the elimination of that condition would mean. I grew up going on camping trips with my family and now enjoy the outdoors as a way to disconnect from the bustle of city life and from our technology. One occasion in particular illustrates what that relationship means in practice. This past valentines day my boyfriend and I drove up Angeles Crest Highway for 1 night to enjoy a bottle of wine next to a campfire. There were no screens and we didn't have to listen to cars zooming by from a busy highway. The Rule has served as the legal foundation for the preservation of places like those referenced above; its rescission would represent an unjustified departure from twenty-five years of settled policy. Regarding the Arroyo Seco in the Angeles National Forest, California: The Arroyo Seco IRA, Angeles National Forest, harbors documented occurrences of Southern Mountain Yellow-legged Frog (Rana muscosa, G1, E). The presence of this Endangered species in an area subject to a proposed federal action triggers an independent ESA Section 7 formal consultation obligation that the agency must discharge before proceeding. The Roadless Rule currently functions as the barrier preventing activities that may affect Southern Mountain Yellow-legged Frog (Rana muscosa, E) in the Arroyo Seco IRA. Roads are not built because the rule prohibits them. Timber is not harvested because road access is unavailable. Rescission removes that barrier and enables the full suite of habitat-altering activities. If the agency finalizes rescission without completing formal consultation for Southern Mountain Yellow-legged Frog (Rana muscosa, G1, E) in the Arroyo Seco IRA, it acts in violation of ESA Section 7. Courts have consistently held that failure to consult is an independent basis for setting aside a federal action, regardless of whether actual harm to the species has occurred. "Habitat fragmentation strongly reduced species richness of plants and animals across experiments. Across experiments, average loss was >20% after 1 year, >50% after 10 years, and is still increasing in the longest time series measured (more than two decades). We were struck by the persistence of degradation to biodiversity and ecosystem processes and by the increase in many of the effects over time." — Maine DEP NECEC Follow-up Joint NGO Comments (Appendix B), citing Haddad et al. 2015, 2015 “Habitat fragmentation strongly reduced species richness of plants and animals across experiments. Across experiments, average loss was >20% after 1 year, >50% after 10 years, and is still increasing in the longest time series measured (more than two decades). We were struck by the persistence of degradation to biodiversity and ecosystem processes and by the increase in many of the effects over time. — Maine DEP NECEC Follow-up Joint NGO Comments (Appendix B), citing Haddad et al. 2015, 2015 (https://doi.org/10.1126/sciadv.1500052)” The Department should let the Rule stand. In earnest, Elyse Borst

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