Comment Analysis · Docket FS-2025-0001

FS-2025-0001-373236

Opposes rescissionA2 moderateSubstance 12/24Owed an answerPosted September 13, 2026 On Regulations.gov

In short: The comment establishes that the agency's proposal to rescind the 2001 Roadless Rule is internally inconsistent with its own DEIS data on wildfire ignition rates and cost-benefit analysis, and that the regulatory flexibility analysis and public comment process fail to properly assess impacts on small entities and foreseeable plan amendments.

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

Recreation Tourism Public Use
- “favorite spots to visit and immerse myself in nature”
- “hiking the various trails”
- “recreation losses of at least $6.1 million a year”
- “outfitters, guides and tour operators”
Forest Management Wildfire
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “justifies rescission partly on wildfire and fuels management grounds”
- “far higher fire density on roaded land than inside the affected roadless areas”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent”
- “net present value spanning -$92 million to +$199 million”
- “road system this rescission would expand already carries a $6.9 billion maintenance backlog”
Governance Policy Process
- “structured public comment in a way that contradicts its own scoping decision”
- “transfers the analytical burden to commenters rather than the agency”
- “regulatory flexibility analysis fails by the same measure”

What it names

National Forests: Lassen National Forest Sequoia National Forest

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I am writing this comment to oppose the rescindment of the 2001 Roadless Rule. The regional, state, and national parks of California are some of my favorite spots to visit and immerse myself in nature. Some of my fondest memories are of hiking the various trails, seeing the different ecosystems and wildlife that call these places their homes, and taking pictures of the scenery. Those experiences depend on the protections the 2001 Roadless Area Conservation Rule provides, and I oppose rescinding it. California holds 381 inventoried roadless areas totaling 4,389,760 acres. The trails and wildlife I have sought out across this state and hope to visit in the future, such as Lassen National Forest and Sequoia National Forest, exist in large part because road construction has been kept out of these landscapes. The agency's own record makes clear that opening them is not a neutral act: "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." The proposal nonetheless justifies rescission partly on wildfire and fuels management grounds. I ask that the agency explain why the proposal departs from its own prior findings and reconcile the rescission with the ignition data in its own DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic rationale for rescission is just as difficult to follow. The agency's 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." Against those marginal gains, the agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service while booking recreation losses of at least $6.1 million a year, with a net present value spanning -$92 million to +$199 million. That range cannot establish a net benefit, and the road system this rescission would expand already carries a $6.9 billion maintenance backlog, not to mention the great financial, cultural, recreational, and wildlife loss that this would cause. The agency must reconcile the proposal with those figures before proceeding. The regulatory flexibility analysis fails by the same measure. 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. Across the Pacific Southwest region, which includes California, 1,034 municipal water intakes sit in watersheds containing affected roadless areas, meaning the downstream consequences for small businesses tied to clean water and recreation are not confined to timber counties. The agency reached its no-impact conclusion by spreading losses across every small firm in the sector nationally rather than assessing the outfitters and guides actually holding permits in the affected areas. That methodology should not survive scrutiny. The agency must withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas. Finally, the agency has structured public comment in a way that contradicts its own scoping decision. The proposed rule concedes that subsequent land management plan amendments and revisions "could increase the area where timber harvest and road construction would be allowed," declares changes to plans beyond the scope of the proposal, and then requests public comment on them (91 FR 53830). Asking the public to comment on scenarios the agency has simultaneously declared out of scope transfers the analytical burden to commenters rather than the agency. The foreseeable plan-amendment scenario, including expanded timber harvest area, must be analyzed as part of this action, not deferred. To conclude, I oppose rescinding the 2001 Roadless Rule and ask the agency to take the actions noted above.