Comment Analysis · Docket FS-2025-0001

FS-2025-0001-312276

Opposes rescissionA3 weakSubstance 14/24Owed an answerPosted September 4, 2026 On Regulations.gov

In short: The comment documents specific deficiencies in the agency's analysis of small business impacts and reliance interests, citing the DEIS and Cost Benefit Analysis to show contradictions in the regulatory flexibility analysis, and requests a site-specific environmental analysis and an alternative retaining the 2001 rule for five named roadless areas in the Angeles 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

A3 weak: Substantive, but easier to set aside.

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.
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

Recreation Tourism Public Use
- “love the outdoors and hiking”
- “hike, birdwatch, and enjoy the wildflowers”
- “small outfitters and guides who work this same country”
- “lost recreation benefit at a minimum of $6.1 million a year”
Environmental Protection Biodiversity
- “beautiful land hosting many ecosystems”
- “We, humans, cannot exist in a vacuum without the many species around us”
- “animals were killed or displaced, environments were wiped out”
- “protect it”
Legal Regulatory Framework
- “small-business certification contradicts the analysis”
- “Under Encino Motorcars and Regents, an agency changing course must assess the reliance interests”
- “ask that the agency withdraw the certification”
- “analyze in the DEIS an alternative that retains the 2001 rule's protections”
Water Quality Quantity
- “The ground filters rainwater”
- “depend on rainwater to refill our aquifers”
- “In this mediterraneam climate this is vital”

What it names

National Forests: Angeles National Forest Angeles National Forest
Roadless areas: Arroyo SecoSan Gabriel AddSheep MountainStrawberry PeakWest Fork

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 I've lived in Los Angeles for 50 years and my husband and I love the outdoors and hiking. Since the Angeles National Forest is in our backyard, we have gone there in our RV in many sites in the forest. Specifically we love going to Mount Baldy where we hike, birdwatch, and enjoy the wildflowers in the spring and watching nature change throughout the year. What I photograph out there: "I photograph birds, wildflowers, and nature." I photograph a variety of birds, including grackle, turkey vultures, and so many more. We stay on the trail and cover many trails in the Angeles National Forest. This is beautiful land hosting many ecosystems upon which our human well-being is dependent. We understand now more than ever before. We, humans, cannot exist in a vacuum without the many species around us. We are all interdependent. I want my grandchildren to see this interdepency for themselves and realize it is our job to protect it. The ground filters rainwater. We depend on rainwater to refill our aquifers. In this mediterraneam climate this is vital. I have lived through the terrible fires in January 2025 in Pacific Palisades and Eaton Canyon. Friends lost their homes, animals were killed or displaced, environments were wiped out. And humans and animals were breathing polluted air. We know how to stop this problem from growing - by reducing our Greenhouse gases and increasing natural solutions. Our forests help us do this. We don't have many roadless areas left. We cannot develop them for short term gain when we now that this is not in our long term interests. We are already behind in repairing the roads that we have. It does not make fiscal sense to build more roads when we cannot keep up with those we have. I do not want my taxes to go to this. I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule, and specifically about these inventoried roadless areas: - San Gabriel Add (2,527 acres), Angeles NF, California - Sheep Mountain (21,098 acres), Angeles NF, California - Arroyo Seco (4,703 acres), Angeles NF, California - West Fork (1,169 acres), Angeles NF, California - Strawberry Peak (7,245 acres), Angeles NF, California I ask that the agency disclose and analyze the site-specific environmental consequences of the proposed rescission for each of these areas, including the effects of the road construction and timber harvest it would newly allow. I raise the following issues for the record and ask that the agency respond to each of them: Issue 1: The small-business certification contradicts the analysis beside it I hike and camp in these areas, and the small outfitters and guides who work this same country help people like me get out there. They deserve a real assessment. 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. The supporting regulatory flexibility analysis reaches its no-impact conclusion by spreading the $9 million annual expenditure loss across every small firm in the sector nationally, rather than assessing the outfitters and guides actually holding permits in the affected areas, and concedes some firms may lose these receipts. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. Issue 2: Reliance interests are invited and never assessed I plan trips into these areas year after year, counting on the protection that keeps them what they are. That reliance is exactly what the agency asked commenters to describe. 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 Encino Motorcars and Regents, an agency changing course must assess the reliance interests its prior policy created. This comment is such an interest. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one. I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule's protections for the areas named above. Where this proposal rests on factual conclusions that differ from the agency's own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record. Sincerely, Cipra Nemeth Los Angeles, CA