Comment Analysis · Docket FS-2025-0001

FS-2025-0001-471331

Opposes rescissionA2 moderateSubstance 14/24Owed an answerPosted September 23, 2026 On Regulations.gov

In short: The comment establishes that the proposed rescission of the Roadless Area Conservation Rule contradicts the agency's own DEIS data showing human-caused fire density is 22.4 per million acres on roaded land versus 3.0 in roadless areas, and that the economic justification is unsupported given a net present value range of -$92 million to +$199 million and a $6.9 billion road maintenance backlog.

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

Forest Management Wildfire
- “opposing the rescission of the 2001 Roadless Area Conservation Rule”
- “The removal of the roadless rule would make us more vulnerable to wildfires, not less”
- “human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas”
- “The wildfire argument the agency offers for rescission contradicts the agency's own findings”
Recreation Tourism Public Use
- “my love for the the mountain bike trails I ride in summer and the backcountry I ski in winter”
- “recreation losses of at least $6.1 million a year”
- “the forest and the backcountry that define the place I call home”
Economic Impact Fiscal
- “The economics also do not make sense”
- “net present value ranging from -$92 million to +$199 million, a range so wide it cannot establish a net benefit”
- “expanding a road system already carrying a $6.9 billion maintenance backlog is fiscally responsible”
Legal Regulatory Framework
- “The agency must explain on the record why this proposal departs from its own prior findings”
- “The administrative-burden rationale for rescission does not hold together”
- “A claim of burden that cannot be itemized is not a basis for rescinding a rule”

What it names

National Forests: Humboldt-Toiyabe National Forest Tahoe National Forest

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeAnalytical gapEvidenceRequestAlternative

I live in Zephyr Cove, Nevada that sits near the Humboldt-Toiyabe National Forest and the Tahoe National Forest. I spend all summer and fall worried about forest fires. Reno battled four fires in the span of one month, all of which were human caused because the landscape is so vulnerable to fire. That experience, as well as my love for the the mountain bike trails I ride in summer and the backcountry I ski in winter, are why I am filing this comment opposing the rescission of the 2001 Roadless Area Conservation Rule. The removal of the roadless rule would make us more vulnerable to wildfires, not less. The wildfire argument the agency offers for rescission contradicts the agency's own findings. The record 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." The region where I live and recreate is exactly the kind of landscape this sentence describes, and the fires Reno/Tahoe has seen this year were all human caused, not lightning caused. The agency must explain on the record why this proposal departs from its own prior findings on fire occurrence in roadless areas, and must reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. The agency's own effects analysis makes the same point with numbers: "Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014–2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads." The gap between 22.4 and 3.0 is not a rounding error; it is the central fact the proposal fails to address. I ask that the agency quantify the expected increase in human-caused ignitions that would follow from new road access and weigh that number honestly against whatever reduction in wildfire hazard it claims to achieve. The economics also do not make sense. Its own analysis concedes 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." Fractions of a percent in national supply are the justification for opening lands that include country where I bike and snowboard. Against that, the agency's own cost-benefit analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year, recreation losses of at least $6.1 million a year, and a net present value ranging from -$92 million to +$199 million, a range so wide it cannot establish a net benefit. I ask the agency to reconcile the rescission with those figures and to explain how expanding a road system already carrying a $6.9 billion maintenance backlog is fiscally responsible when its own analysis cannot confirm the action pays. My answer to the maintenance question is a simple one: how will these new roads be maintained when the existing ones are already behind? That is not a rhetorical point; it is a planning question the proposal does not answer. Finally, the administrative-burden rationale for rescission does not hold together when the rule's own text is read carefully. The rule "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. § 294.12(b)(1),(3)." Emergency access, existing mineral leases, community wildfire protection work: the exceptions are already there. The agency should identify on the record which specific administrative burdens are not addressed by those existing exceptions, and it should quantify them. A claim of burden that cannot be itemized is not a basis for rescinding a rule that protects millions of acres and, from where I stand, the forest and the backcountry that define the place I call home.