Comment Analysis · Docket FS-2025-0001

FS-2025-0001-329809

Opposes rescissionA1 strongSubstance 17/24Owed an answerPosted September 7, 2026 On Regulations.gov

In short: The comment establishes that the agency's proposal to rescind the Roadless Area Conservation Rule is internally inconsistent with its own DEIS data on fire density and economic net present value, fails to quantify administrative burdens not covered by existing regulatory exceptions, and violates NEPA by foreclosing a meaningful alternatives analysis through a deregulatory purpose statement.

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

A1 strong: Must be answered — it names the law.

Owed an answer on Analytical gap, Evidence, Legal.

Standard dismissals it defeats

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.
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.
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.

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.
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.

Topics

Forest Management Wildfire
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “rescission partly on the grounds that it will improve fuels management”
- “roads bring more human ignitions, not fewer”
- “reconcile the rescission with the ignition data in DEIS Table 21”
Water Quality Quantity
- “Clean water is more than life-giving; it should and must be a right of every American”
- “1,034 municipal water intakes sit in watersheds containing affected roadless areas”
- “roads and their facilities can produce up to 90 percent of the sediment from a timber sale”
- “drain into a watershed system that supplies one of the most water-stressed urban regions”
Governance Policy Process
- “alternatives analysis is not a real alternatives analysis”
- “Alternatives with more protection were dismissed as not responsive to the deregulatory executive orders”
- “purpose statement written as a directive to deregulate forecloses the comparison NEPA requires”
- “agency must restate the purpose and need in terms of actual on-the-ground conditions”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “net present value of the action spans -$92 million to +$199 million”
- “expand a road system already carrying a $6.9 billion maintenance backlog”
- “agency cannot establish a net benefit with its own numbers”

What it names

National Forests: Angeles National Forest
Roadless areas: Arroyo SecoSan Dimas
Law cited: 36 C.F.R. Section 294.12

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 The natural environment should be protected for needed resources and habitats and for the future of future generations. That is the standard I hold my public land managers to, and the proposed rescission of the 2001 Roadless Area Conservation Rule fails it completely. I oppose this action and ask that my comments be entered into Docket FS-2025-0001. The agency's own evidence on fire is the place to start. 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." I live in California, where the Arroyo Seco and San Dimas roadless areas within Angeles National Forest sit inside a landscape that needs no introduction to the consequences of wildfire. The agency now proposes rescission partly on the grounds that it will improve fuels management, while its own record documents that roads bring more human ignitions, not fewer. I ask that the agency explain why this proposal departs from its own prior findings on fire occurrence in roadless areas, and that it reconcile the rescission with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The economics do not hold together either. The agency's own record acknowledges that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." I want my tax dollars spent on protecting and preserving the natural environment, not on exploitation and extraction of treasured resources. That principle takes on specific weight when the agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service set against recreation losses of at least $6.1 million a year, and when the net present value of the action spans -$92 million to +$199 million. The agency cannot establish a net benefit with its own numbers, yet it proposes to expand a road system already carrying a $6.9 billion maintenance backlog. I ask that the agency reconcile the proposal with those figures and explain how an action whose own analysis cannot confirm a net benefit is justified. Clean water is more than life-giving; it should and must be a right of every American. Across the Pacific Southwest region, which includes California, 1,034 municipal water intakes sit in watersheds containing affected roadless areas, according to DEIS Table 35. The Arroyo Seco and San Dimas areas drain into a watershed system that supplies one of the most water-stressed urban regions in the country. The agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale. The rule as written already addresses the hardship cases the agency invokes as justification: it "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." If existing exceptions already cover public health and safety, the agency should say so plainly and identify which specific burdens are not already addressed by those provisions. It has not done that. I ask that the agency quantify the claimed administrative burdens that fall outside the rule's existing exceptions and put that accounting before the public. Finally, the alternatives analysis is not a real alternatives analysis. Protective options were not weighed against the proposal on the merits of forest conditions. Instead, the agency built its purpose around deregulation and eliminated anything that did not fit: "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.'" A purpose statement written as a directive to deregulate forecloses the comparison NEPA requires. The Arroyo Seco and San Dimas areas, and the habitats and water resources they contain, deserve analysis that begins with forest conditions, not with a predetermined outcome. The agency must restate the purpose and need in terms of actual on-the-ground conditions and analyze at least one full protective alternative before this rulemaking proceeds. Sincerely, Paul Irving Los Angeles, California