Comment Analysis · Docket FS-2025-0001

FS-2025-0001-456927

Opposes rescissionA1 strongSubstance 14/24Owed an answerPosted September 21, 2026 On Regulations.gov

In short: The comment places on the record specific deficiencies in the agency's analysis, including the failure to reconcile the proposal with its own ignition data in DEIS Table 21, the lack of public meetings to justify rescission despite the 2001 rule's extensive process, and the failure to explain how the proposal avoids the legal deficiencies previously identified by the Ninth Circuit.

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

Governance Policy Process
- “without holding a single public meeting to justify it”
- “held more than 600 public meetings and took 1.6 million comments to write the 2001 Roadless Area Conservation Rule”
- “explain how this proposal avoids the deficiencies the Ninth Circuit identified then”
Forest Management Wildfire
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “reconcile the proposal with its own ignition data in DEIS Table 21”
- “far higher fire density on roaded land than inside the affected roadless areas”
Wildlife Habitat
- “bird richness declines with road presence in forested habitat”
- “road-noise experiments in a roadless area cut bird abundance by over a quarter”
- “shelter birds and wildlife”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “net present value spanning -$92 million to +$199 million”
- “expanding a road system already carrying a $6.9 billion maintenance backlog”

What it names

Roadless areas: Santa Cruz
Law cited: 28 U.S.C. Section 1291

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Redwood parks and trails shaped how I think about public land. I have hiked in numerous redwood parks and others, biked through nature away from civilization, photographed nature scenes rather than roads, and found that seeing wild animals and birds is a unique treat. What I am asking this agency to do is explain, specifically and on the record, why it intends to undo a rule that has protected these places for more than two decades without holding a single public meeting to justify it. The Forest Service held more than 600 public meetings and took 1.6 million comments to write the 2001 Roadless Area Conservation Rule. It has held none to rescind it. I do not want my children to inherit fewer nature areas to visit than I have had, and I do not see how this agency can justify that outcome without at minimum confronting the evidence in its own record. On wildfire, the agency's own draft environmental impact statement states: "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." If the justification for rescission includes fuels management, that finding demands an answer. I ask that the agency reconcile the proposal with its own ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas, and explain why the proposal departs from those prior findings. On economics, the 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." 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 -$92 million to +$199 million. I think logically about this: we are very behind on current road maintenance, and the answer cannot be new roads. The agency must explain how an action whose own analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog. On birds, the DEIS cites findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. Encountering birds in unroaded country is exactly the kind of experience that disappears when roads arrive, and no logged stand or rebuilt trail returns what a road network removes. The agency has not explained how this documented harm to bird communities factors into its decision. On the prior state-by-state approach, the agency's own record acknowledges that the USDA "discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The agency tried replacing the national rule with state-specific approaches before and that effort was overturned. I ask that the agency explain how this proposal avoids the deficiencies the Ninth Circuit identified then, and address its own prior finding that local decision-making can incrementally erode nationally significant roadless values. On statutory authority, the Tenth Circuit held: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." That court found the 2001 rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. The agency owes a clear explanation of the legal basis for any position to the contrary. Public land should be properly protected for all of us. Roadless areas protect our watersheds, shelter birds and wildlife, and give people places to travel away from roads and development. I oppose this rescission and expect the agency to respond specifically to each of these points before proceeding further. Sincerely, Kathleen Kernan Santa Cruz, CA