Comment Analysis · Docket FS-2025-0001

FS-2025-0001-303267

Opposes rescissionA2 moderateSubstance 13/24Owed an answerPosted September 2, 2026 On Regulations.gov

In short: The comment establishes that the agency's proposal to rescind the Roadless Rule contradicts its own DEIS data regarding fire density on roaded lands, ignores documented wildlife corridors used by jaguars, relies on a flawed regulatory flexibility analysis that averages national losses rather than assessing specific permit holders, and fails to weigh reliance interests created by the 2001 rule.

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
- “jaguars have been documented crossing from Mexico”
- “Verified species of the Coronado sky islands include jaguar, elegant trogon, Mexican spotted owl”
- “roadless corridors as the only viable pathway for the northernmost extent of jaguar range”
- “connective tissue between sky islands”
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”
- “Opening these corridors to roads does not protect them”
- “far higher fire density on roaded land than inside roadless areas”
Legal Regulatory Framework
- “an approach the Ninth Circuit rejected”
- “explain how this proposal avoids the legal deficiencies that defeated the prior state-by-state replacement”
- “Under the principles the Supreme Court articulated in Encino Motorcars and Regents”
- “agency changing a longstanding rule must identify and genuinely weigh the reliance interests”
Recreation Tourism Public Use
- “go there to escape the summer heat”
- “lost recreation benefit at a minimum of $6.1 million a year”
- “outfitters, guides, and tour operators as affected”
- “where to hike, and what they value about a place like Mount Lemmon”

What it names

National Forests: Coronado National Forest
Roadless areas: Catalina St. Pk. Roadless AreaOracle Roadless

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 Mount Lemmon is right down the road from me, and I go there to escape the summer heat, a sky island oasis rising out of the desert. The Catalina St. Pk. Roadless Area in the Coronado National Forest is part of what makes that escape possible: water in the desert, wildflowers, so many animals. Parts of the mountain have burned before, and the smallness of that cool zone, surrounded by hot desert, is exactly what makes losing any of it so serious. I am writing to oppose the rescission of the 2001 Roadless Area Conservation Rule under Docket FS-2025-0001, and I ask that each point below be answered in the final record. The agency's stated rationale includes wildfire and fuels management, but its own prior findings cut against that rationale. The DEIS 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 Coronado holds 23 inventoried roadless areas totaling 482,687 acres, including the Catalina St. Pk. Roadless Area, the Oracle Roadless area, and the Romero WSR units. I have watched fire take pieces of a mountain that has nowhere else to go. Opening these corridors to roads does not protect them; the agency's own ignition data, reported in DEIS Table 21, shows far higher fire density on roaded land than inside roadless areas. I ask the agency to explain why this proposal departs from those prior findings and to reconcile the rescission with that data. The proposal argues that state-by-state approaches can substitute for a single national rule. But the agency has tried that before. Without reproducing language from a prior rulemaking, the record shows the agency previously expressed dissatisfaction with a uniform national approach and moved toward state-specific petitions, an approach the Ninth Circuit rejected. The Coronado's roadless areas are not isolated parcels; they are the connective tissue between sky islands, and jaguars have been documented crossing from Mexico through the Santa Ritas into the Rincon Mountains and beyond, using those roadless corridors as the only viable pathway for the northernmost extent of jaguar range. Verified species of the Coronado sky islands include jaguar, elegant trogon, Mexican spotted owl, Gould's turkey, Arizona treefrog, and ocelot. A species that crosses state lines and international borders is not well served by a patchwork of state petitions. The agency must explain how this proposal avoids the legal deficiencies that defeated the prior state-by-state replacement. The agency's regulatory flexibility analysis certifies no significant impact on small entities while the DEIS identifies outfitters, guides, and tour operators as affected, and the Cost Benefit Analysis records lost recreation benefit at a minimum of $6.1 million a year. Across Arizona, there are 78 inventoried roadless areas totaling 1,174,256 acres, and 739 municipal water intakes in the Southwestern region sit in watersheds containing affected roadless areas. The certification reaches its no-impact conclusion by spreading losses across every small firm in the sector nationally rather than examining the outfitters and guides actually holding permits in these areas. That methodology cannot produce a meaningful finding. The agency should withdraw the certification and assess the actual permit holders operating in and around areas like the Catalina St. Pk. Roadless Area and the Oracle Roadless area, not a national average. Finally, this comment is itself a reliance interest. 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. Under the principles the Supreme Court articulated in Encino Motorcars and Regents, an agency changing a longstanding rule must identify and genuinely weigh the reliance interests its prior policy created. People who chose where to live, where to hike, and what they value about a place like Mount Lemmon have organized expectations around protections that have been in place since 2001. The agency should identify and weigh the reliance interests described in the comments it receives, including this one. Sincerely, Kasey Bellafiore