Comment Analysis · Docket FS-2025-0001

FS-2025-0001-313597

Opposes rescissionA2 moderateSubstance 17/24Owed an answerPosted September 4, 2026 On Regulations.gov

In short: The comment places on the record specific data from DEIS Table 21 regarding human-caused ignition densities, identifies a methodological flaw in the small entity certification by noting it spreads losses nationally rather than examining local permit holders, and asserts that the agency failed to weigh solicited reliance interests or properly analyze protective alternatives under NEPA.

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, Alternative.

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

Recreation Tourism Public Use
- “find serenity in an increasingly busy world”
- “love of getting outside rather than staying indoors behind screens”
- “lost recreation benefit at a minimum of $6.1 million a year”
- “outfitters, guides and tour operators as affected”
Governance Policy Process
- “NEPA requires a genuine comparison of alternatives”
- “certifies no significant impact on small entities”
- “weighs none of them [reliance interests]”
- “asymmetry alone should give the agency pause”
Forest Management Wildfire
- “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”
- “human-caused ignitions increase in abundance with proximity to roads”
- “quantify the expected increase in human-caused ignitions from new road access”
- “roads that already exist be safe and well-maintained”
Environmental Protection Biodiversity
- “less and less undisturbed nature remaining”
- “Roadless areas in the national forests are among the last places where that balance still holds”
- “Removing the rule that protects them tips it in the wrong direction”
- “maintain for our kids, their kids, and down the line for decades to come”

What it names

National Forests: Stanislaus National Forest

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 Stanislaus National Forest is where I go to find serenity in an increasingly busy world. I love hiking there and visiting Yosemite when I'm in that area. It is how I connect with nature, and it is what I am trying to pass on to my kids. One of the values I am working to share with them is a love of getting outside rather than staying indoors behind screens. Our national forests are one of the last and best places to do that, and something we should maintain for our kids, their kids, and down the line for decades to come. This proposed rescission threatens that, and I am writing to oppose it. Our public land should be managed for the public good. We have less and less undisturbed nature remaining, and that has to be part of the balance around land use in the big picture. Roadless areas in the national forests are among the last places where that balance still holds. Removing the rule that protects them tips it in the wrong direction. On the question of roads and maintenance: I would much rather see the roads that already exist be safe and well-maintained rather than see an increasing number of roads that are accident-prone or potentially damaging to vehicles. The agency is already behind on maintaining what it has. Building into country that currently has none does not solve that problem. I ask the agency to explain, on the record, how adding new road infrastructure into unroaded areas is consistent with its existing maintenance backlog. "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 outfitters and guides who hold permits in areas like the Stanislaus are the ones who would feel that loss directly, not some national average firm. The certification reaches its conclusion by spreading the projected expenditure loss across every small business in the sector nationally rather than examining the actual permit holders in the affected areas. That is not a meaningful analysis. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas. "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." I am one of those reliance interests. I have built a relationship with Stanislaus National Forest and brought my children to places like it because the rule has kept those places intact. When an agency reverses a policy it has held for decades, it must account for what people and businesses have built around that policy. The agency solicited these interests and then weighed none of them. I ask that it identify and weigh the reliance interests described in the comments it receives, including this one. "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's own data undercuts the argument that removing roadless protections reduces fire risk. The effects analysis concedes that road access could increase the number and frequency of wildfires, yet no estimate of that increase appears alongside the claimed reduction in wildfire hazard. The agency must quantify the expected increase in human-caused ignitions from new road access and weigh it against the claimed benefit before finalizing this rule. "Alternatives with more protection were dismissed as not responsive to the deregulatory executive orders, and the keep-boundaries option was cut because it 'would continue to restrict local decision-making discretion' and because analysing roadless values is 'an administrative and legal burden for the agency.'" NEPA requires a genuine comparison of alternatives. A purpose written as deregulation from the start forecloses that comparison. Eliminating a protective alternative because it conflicts with the agency's preferred outcome is not analysis. I ask that the agency restate the purpose and need in terms of actual forest conditions and analyse at least one fully protective alternative before this proceeding moves further. The national forests belong to the public. I am part of that public, and so are my children. This rule was written after more than 600 public meetings and 1.6 million comments. No equivalent process has been held to undo it. That asymmetry alone should give the agency pause. Sincerely, Gregory Pal Mountain View, CA