Comment Analysis · Docket FS-2025-0001

FS-2025-0001-340929

Opposes rescissionA2 moderateSubstance 14/24Owed an answerPosted September 9, 2026 On Regulations.gov

In short: The comment documents that the agency's regulatory flexibility certification relies on national averages rather than local impacts on specific small entities in the Angeles National Forest, fails to weigh solicited reliance interests despite a 24-year history of protection, and ignores DEIS data showing a 7.5:1 ratio of human-caused ignitions on roaded versus roadless land that contradicts the proposal's wildfire rationale.

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

Governance Policy Process
- “agency's own numbers undermine its regulatory flexibility certification”
- “Averaging a harm across thousands of uninvolved businesses to make the harm appear trivial is not analysis”
- “The agency has also invited reliance interests and then declined to weigh them”
- “An agency that changes course after twenty-four years of established protection is obligated to account for the expectations its prior rule created”
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”
- “The agency must quantify the expected increase in human-caused ignitions that new road access would bring”
- “weigh that increase against whatever reduction in wildfire hazard is claimed”
Recreation Tourism Public Use
- “places like the Arroyo Seco roadless area... remain places where people can be with nature for generations”
- “My family camped and hiked there in the summers and sledded and threw snowballs in the winters”
- “My family's decades of recreation in the Arroyo Seco area”
- “expectation that those 4,703 acres would remain protected for future generations”
Water Quality Quantity
- “1,034 municipal water intakes sit in watersheds containing affected roadless areas”
- “California alone holds 381 inventoried roadless areas totaling 4,389,760 acres”

What it names

National Forests: Angeles National Forest
Roadless areas: Arroyo Seco

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 mountains outside Los Angeles shaped my childhood. My family camped and hiked there in the summers and sledded and threw snowballs in the winters, and those experiences left me with a simple, persistent wish: that places like the Arroyo Seco roadless area in the Angeles National Forest remain places where people can be with nature for generations and generations to come. The proposed rescission of the 2001 Roadless Area Conservation Rule threatens that, and I oppose it. The agency's own numbers undermine its regulatory flexibility certification. "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." That certification is reached by averaging the projected expenditure loss across every small firm in the sector nationally, rather than examining the outfitters, guides and tour operators who actually hold permits inside the affected roadless areas, including those serving the Angeles National Forest. The analysis itself concedes that some firms may lose those receipts entirely. Averaging a harm across thousands of uninvolved businesses to make the harm appear trivial is not 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, not the national average firm. The agency has also invited reliance interests and then declined to weigh them. "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." My family's decades of recreation in the Arroyo Seco area, and my expectation that those 4,703 acres would remain protected for future generations, are exactly the kind of reliance interest the solicitation invites. An agency that changes course after twenty-four years of established protection is obligated to account for the expectations its prior rule created, not simply collect comments describing them and set them aside. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one. Finally, the agency's own fire data argues against opening these areas to road construction. "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 Angeles National Forest sits at the edge of one of the most densely populated regions in the country. California alone holds 381 inventoried roadless areas totaling 4,389,760 acres, and across the Pacific Southwest region 1,034 municipal water intakes sit in watersheds containing affected roadless areas. A ratio of nearly eight human-caused ignitions to one between roaded and roadless land is not a footnote; it is a finding that cuts directly against the proposal's stated rationale. The agency must quantify the expected increase in human-caused ignitions that new road access would bring to areas like Arroyo Seco and weigh that increase against whatever reduction in wildfire hazard is claimed, before this rescission can proceed. Sincerely, Los Angeles, CA