Comment Analysis · Docket FS-2025-0001

FS-2025-0001-359700

Opposes rescissionA2 moderateSubstance 11/24Owed an answerPosted September 12, 2026 On Regulations.gov

In short: The comment documents that the agency's rescission proposal is internally inconsistent with its own scientific data on fire ignition in roadless areas, fails to properly assess the economic impact on local small entities despite acknowledging millions in lost recreation benefits, and ignores solicited reliance interests, specifically regarding the Arroyo Seco, Strawberry Peak, and San Gabriel Add 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

A2 moderate: Hard to dismiss — it shows cause and effect.

Owed an answer on Analytical gap.

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
- “hike frequently in this area”
- “pristine views of the San Gabriel Mountains”
- “lost recreation benefit at a minimum of $6.1 million a year”
- “scenic trails and rugged slopes that draw visitors”
Forest Management Wildfire
- “ignitions are almost twice as likely to occur in roaded areas”
- “Opening these landscapes to roads would bring exactly the ignition risk”
- “allows tree cutting in non-upper tier within 0.5 miles”
- “temporary road may be constructed to facilitate hazardous fuel reduction”
Environmental Protection Biodiversity
- “unspoiled, rugged slopes would be fundamentally altered by roads”
- “genuinely wild region of forest where the city disappears entirely”
- “destroy the unique wilderness character of these areas”
- “conserved adjacent land and understood these landscapes as protected”
Governance Policy Process
- “reconcile the rescission with the ignition density data in its own DEIS”
- “quantify those burdens with evidence rather than assertion”
- “withdraw that certification and conduct a meaningful assessment”
- “genuinely weigh the reliance interests submitted in this comment period”

What it names

National Forests: Angeles National Forest
Roadless areas: Arroyo SecoSan Gabriel AddStrawberry Peak

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Arroyo Seco roadless area is a treasure to our community. Living in Altadena and working in Pasadena, I hike frequently in this area, and having 4,703 acres of roadless land so close to home matters in ways that are difficult to overstate. The 7,245-acre Strawberry Peak area, which I have summitted multiple times, offers pristine views of the San Gabriel Mountains, and its unspoiled, rugged slopes would be fundamentally altered by roads. The 2,527-acre San Gabriel Add, though close to Los Angeles, carries you deep into a genuinely wild region of forest where the city disappears entirely. I am filing this comment to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001) because each of these places in the Angeles National Forest, and the communities that depend on them, would be harmed by that rescission. The agency's stated rationale rests in part on wildfire and fuels management concerns, yet the agency's own record undermines that justification. According to the Forest Service, "more than 90 percent of wildland fires are the result of human activity, and ignitions are almost twice as likely to occur in roaded areas as they are in roadless areas (USDA Forest Service 1998, 2000)." The Arroyo Seco and Strawberry Peak areas I hike regularly sit in a region where fire is a constant threat to nearby communities. Opening these landscapes to roads would bring exactly the ignition risk the agency's own science identifies. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence in roadless areas, and that it reconcile the rescission with the ignition density data in its own DEIS. The agency also suggests the current rule creates administrative and permitting burdens that rescission would relieve. That justification is difficult to square with what the rule actually allows. The rule states: "The rule recognizes the need for tree cutting to reduce the risk of wildfire to at-risk communities. It allows tree cutting in non-upper tier within 0.5 miles from the boundary of an at-risk community, or up to 1.5 miles if certain conditions exist and the area is within a Community Wildfire Protection Plan (CWPP). A temporary road may be constructed to facilitate hazardous fuel reduction within 0.5 miles of the boundary of an at-risk community." The communities near the Angeles National Forest, including those I live and work in, are already served by these provisions. Introducing permanent roads into the San Gabriel Add or across the slopes of Strawberry Peak to accomplish what a temporary road already can accomplish would destroy the unique wilderness character of these areas without any demonstrated necessity. I ask the agency to identify, specifically and on the record, which burdens are not already addressed by the rule's existing exceptions for public health, safety, existing mineral leases and community wildfire protection, and to quantify those burdens with evidence rather than assertion. The regulatory flexibility analysis accompanying this proposal certifies no significant impact on small entities, yet the agency's own DEIS names outfitters, guides and tour operators as affected parties, and the Cost Benefit Analysis records lost recreation benefit at a minimum of $6.1 million a year. That certification was reached by spreading estimated losses across every small firm in the sector nationally rather than assessing the outfitters and guides who actually hold permits and operate inside the affected roadless areas. The scenic trails and rugged slopes that draw visitors to Strawberry Peak and the Arroyo Seco support exactly those kinds of businesses. The agency cannot in good faith certify no significant impact on the firms most directly exposed while simultaneously booking millions in annual recreation losses in the same document. The agency must withdraw that certification and conduct a meaningful assessment of the small entities actually operating in these areas. Finally, 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. For over two decades, communities near these Angeles National Forest roadless areas have planned recreation, conserved adjacent land and understood these landscapes as protected. 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. The reliance that has accumulated across that landscape is real and quantifiable. The agency invited those interests and then ignored them in its own analysis. It must identify and genuinely weigh the reliance interests submitted in this comment period before taking any final action. Sincerely, Dr. Charles D Edwards, Jr Altadena, CA 91001