Comment Analysis · Docket FS-2025-0001

FS-2025-0001-345232

Opposes rescissionA2 moderateSubstance 15/24Owed an answerPosted September 12, 2026 On Regulations.gov

In short: The comment documents that the agency's proposal to rescind the 2001 Roadless Area Conservation Rule fails to reconcile its regulatory analysis with its own DEIS data regarding small entity impacts, wildfire ignition densities, and habitat fragmentation, specifically requesting that the agency withdraw its small entity certification, quantify wildfire risks, and apply fragmentation findings to the 40.1 million acres of potentially affected environment.

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

Water Quality Quantity
- “removing riparian vegetation can raise stream temperatures”
- “reduce egg survival, rearing densities and growth of coho salmon”
- “Essential Fish Habitat and critical habitats managed by NMFS”
- “North Fork American River corridor covers 38,495 acres”
Wildlife Habitat
- “Wild areas need to stay wild so that wildlife has room to roam”
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
- “amazing resource for wildlife”
- “keep it pure, keep the roadless rule”
Recreation Tourism Public Use
- “I want my kids and my grandkids to see nature undisturbed by roads”
- “lost recreation benefit at a minimum of $6.1 million a year”
- “people who know them, who raft them, who photograph them”
- “outfitters and guides operating on rivers like the American have direct financial exposure”
Forest Management Wildfire
- “Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land”
- “human-caused ignitions increase in abundance with proximity to roads”
- “We can't maintain current roads. Why build more?”
- “quantify the expected increase in human-caused ignitions that new road access would bring”

What it names

National Forests: Eldorado National Forest Tahoe National Forest
Roadless areas: North Fork American RiverNorth Fork Middle Fork American River

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapEvidenceLegal

The Sierra Nevada is where I hike and camp, and the American River is where I raft. I also run the Grand Canyon, the Salmon River in Idaho, the Tat in Alaska, and others. Love the water. The North Fork American River in the Tahoe National Forest is an amazing resource for wildlife. The North Fork Middle Fork American River, also in the Tahoe, is magic. The Rubicon in the Eldorado National Forest is part of the same fabric of forests and parks I visit in my area and outside it. I want my kids and my grandkids to see nature undisturbed by roads. The agency should understand that when it proposes to rescind the 2001 Roadless Area Conservation Rule under Docket FS-2025-0001, it is not acting in a vacuum. These places have people who know them, who raft them, who photograph them knowing photos do not do them justice, and who have expected the rule to hold. Wild areas need to stay wild so that wildlife has room to roam as nature intended. Roads change that. The North Fork American River corridor covers 38,495 acres in the Tahoe National Forest. Research the agency itself has in hand confirms that removing riparian vegetation can raise stream temperatures beyond what suits cold-water species, and that warmer temperatures can reduce egg survival, rearing densities and growth of coho salmon, with the affected area including Essential Fish Habitat and critical habitats managed by NMFS. The Salmon River is one of the rivers I run. The connection between road building, riparian disturbance, and cold-water fish survival is not speculative; it is in the agency's own record. I ask the agency to explain specifically how the 38,495 acres of the North Fork American River roadless area, and the Essential Fish Habitat within it, would be protected from those documented effects if the rule is rescinded. The regulatory analysis accompanying this proposal cannot be reconciled with the data beside it. 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. Outfitters and guides operating on rivers like the American have direct financial exposure to any degradation of the roadless character that draws clients. The certification is reached by averaging losses across every small firm in the sector nationally rather than examining the firms holding permits in the affected areas. 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 explicitly invited reliance interests into this record and then set them aside. 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. This comment is one such interest. The rule has been in place long enough that people plan around it, choose where to raft and hike and photograph based on it, and pass that expectation to their children. The agency must identify and weigh those interests before it can rationally change course. We can't maintain current roads. Why build more? The Forest Service is already billions behind on road maintenance, and the agency's own fire data makes the case for restraint even sharper. 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 11,245 acres of the North Fork Middle Fork American River and the 4,872 acres of the Rubicon sit inside that low-ignition zone now. The agency should quantify the expected increase in human-caused ignitions that new road access would bring and weigh it honestly against any claimed reduction in wildfire hazard before this proposal moves further. Finally, The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. That range is placed in the record and then left there. No projection is applied to the 40.1 million acres of potentially affected environment. Keep it pure, keep the roadless rule: that is my position, and the agency's own fragmentation finding, unapplied at scale, does nothing to contradict it. The agency must apply the cited fragmentation range to the full 40.1 million acres of potentially affected environment and show what the analysis actually means at that scale. Sincerely,