Comment Analysis · Docket FS-2025-0001

FS-2025-0001-443582

Opposes rescissionA1 strongSubstance 9/24Owed an answerPosted September 17, 2026 On Regulations.gov

In short: The comment establishes that the agency's analysis fails to account for net benefits as required by Executive Order 12866, while documenting specific economic losses from logging, threats to water quality in Southern California, and the increased wildfire risk associated with road construction.

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, 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

  • Recreation Tourism Public Use
    • “climbed 140 peaks over 5000 feet”
    • “43,000 miles of trails, 11,000 climbing routes, and 1,000 whitewater rafting runs”
    • “Tourism would suffer, when people no longer visit former roadless areas that have been spoiled”
  • Water Quality Quantity
    • “most of our water supply originates in these Roadless Areas”
    • “high quality water is essential to the success of businesses”
    • “Opening these Roadless Areas to roadbuilding or mineral development threatens this clean water”
  • Economic Impact Fiscal
    • “USFS spent $388 million on its Forest Products program and only collected $41 million in receipts”
    • “Tongass Forest logging program cost US taxpayers $1.73 billion”
    • “Roadless lands generate a net benefit estimated to be $24 billion a year”
  • Forest Management Wildfire
    • “Roads are ignition corridors! 89% of wildfires nationally are human-caused”
    • “The 2001 Roadless Rule DOES allow fuel treatments”
    • “Fix what has already been built, before you build more roads”

What it names

Law cited
Executive Order 12866
Works cited
Johnston et al. 2023

The comment

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

I have climbed 140 peaks over 5000 feet in Southern California, over 25 in the Sierra Nevada, and about a dozen in the California Desert. This has created both a lot of enjoyment and a lot of economic activity. Roadless areas include 43,000 miles of trails, 11,000 climbing routes, and 1,000 whitewater rafting runs that bring visitors and billions of dollars to small towns across America. That stops if these roadless areas are logged or mined. The economic benefits of the areas protected by the 2001 Roadless Rule far outweigh the benefits of rescission of this rule. In Southern California, most of our water supply originates in these Roadless Areas or adjacent Wilderness areas. This high quality water is essential to the success of businesses in Southern California. Opening these Roadless Areas to roadbuilding or mineral development threatens this clean water. As a taxpayer, I resent that the Forest Service processes and approves logging that costs me money. In the 2018 fiscal year, the USFS spent $388 million on its Forest Products program and only collected $41 million in receipts. This is an outrageous waste of taxpayer money, when the undeveloped forest has so many beneficial uses. The Tongass Forest logging program cost US taxpayers $1.73 billion between 1980 and 2019!! Executive Order 12866 requires an accounting of NET benefits, not gross receipts. Why has this not been done?? Roadless lands generate a net benefit estimated to be $24 billion a year, a permanent annual dividend from these undeveloped roadless lands. Trading that for a one-time logging or mineral development is not worth the loss of these roadless lands. Local decision-making often results in loss of national values. A local Forest Service Supervisor might please local residents when roadless areas are developed. But national values of those lands would be lost. Tourism would suffer, when people no longer visit former roadless areas that have been spoiled. Why would the Forest Service want to build ANY roads, when there is a $6.0 billion maintenance backlog on the roads that already exist??? Fix what has already been built, before you build more roads that the taxpayer can not afford to maintain!! The FS spends a huge amount of money on fire fighting. Roads are ignition corridors! 89% of wildfires nationally are human-caused. I was nearly trapped by the Caldor Fire in the Sierra Nevada in 2021. A home on my cul de sac was burned to the ground by the 2008 Freeway Complex Fire. Both of these were human-caused. The 2001 Roadless Rule DOES allow fuel treatments, as shown by over 2 million acres or roadless lands being treated. The fuels treatment is limited by appropriations and workforce capacity, not the fact that these lands are roadless. Stop the insanity! Do NOT rescind the 2001 Roadless Rule!!

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