Comment Analysis · Docket FS-2025-0001

FS-2025-0001-449052

Opposes rescissionA1 strongSubstance 17/24Owed an answerPosted September 21, 2026 On Regulations.gov

In short: The comment establishes that the agency's proposal to rescind the Roadless Area Conservation Rule is inconsistent with its own DEIS findings regarding wildfire ignition rates on roaded lands, its cost-benefit analysis showing no clear net economic benefit, and its own data on bird abundance declines, while noting that existing regulatory exceptions already address public safety and water protection needs in specific locations like Coconino and Kaibab National Forests.

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, Evidence, 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

Wildlife Habitat
- “bird abundance dropped by over a quarter”
- “31 percent of species avoided the noise entirely”
- “bird richness declines with road presence”
- “old growth tree stands in these canyons”
Forest Management Wildfire
- “Building roads through National Forests will exacerbate the already-worsening fire seasons”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “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 of total United States production”
- “recreation losses of at least $6.1 million a year”
- “$6.9 billion road maintenance backlog”
- “economic projections that the agency's own numbers cannot validate”
Water Quality Quantity
- “739 municipal water intakes sit in watersheds containing affected roadless areas”
- “watershed protection”

What it names

Roadless areas: Coconino RimEast Clear CreekJacks CanyonLeonard CanyonLower Jacks CanyonPadre CanyonPonderosa Pine
Law cited: 36 C.F.R. Section 294.12

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 sounds of nature, the birds in the trees, the smell of the Ponderosa pine, the quiet and the clean fresh air: that is what I go to my nearby National Forest for, and that is what this proposal would put at risk. I am opposing the rescission of the 2001 Roadless Area Conservation Rule. The wildfire argument for rescission collapses against the agency's own findings. I live near the Coconino and Kaibab National Forests, and I watched what the 30,000 acre Pocket Fire did to this landscape. Building roads through National Forests will exacerbate the already-worsening fire seasons dramatically. The agency itself agrees with that concern, writing: "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 agency must explain why this proposal departs from that finding, and must reconcile the rescission with the ignition data in its own DEIS, which reports far higher fire density on roaded land than inside the affected roadless areas. The birds I listen for in areas like Coconino Rim, East Clear Creek, Padre Canyon, Lower Jacks Canyon, Jacks Canyon, and Leonard Canyon are not incidental to my reason for being there. They are the reason. The agency's own record, citing research on road-noise experiments in roadless areas, found that bird abundance dropped by over a quarter and that 31 percent of species avoided the noise entirely, and that bird richness declines with road presence in forested habitat. Roads do not pass quietly through a forest. They reorganize it. I ask that the agency explain what weight it gave these findings when weighing the costs to bird communities across Arizona's 78 inventoried roadless areas totaling 1,174,256 acres, and whether any mitigation measure in this proposal is designed to address them. The economic case for rescission does not hold up either. The agency's own record states 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 that, the agency's own cost-benefit analysis projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year, with a net present value spanning negative $92 million to positive $199 million. The agency also carries a $6.9 billion road maintenance backlog on the system it already has. The agency must explain on the record how a proposal whose own analysis cannot establish a net benefit justifies expanding that road system further. The rule as written already accommodates urgent needs. Its own text makes clear that it "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." Across the Southwest, 739 municipal water intakes sit in watersheds containing affected roadless areas. Community safety, existing rights, watershed protection: the rule's exceptions already speak to these things. The agency must identify, specifically and by category, which burdens the existing exceptions do not address, and must quantify those burdens in the record before moving forward. We have done enough damage to this country's natural resources. The old growth tree stands in these canyons and on these rims are older than all of us. The roadless protections that have kept them intact reflect a straightforward judgment: some values are worth keeping. Rescinding the rule trades those values for economic projections that the agency's own numbers cannot validate. I urge the agency to withdraw this proposal. Sincerely, Sam Axford Flagstaff, Arizona