Comment Analysis · Docket FS-2025-0001

FS-2025-0001-489115

Opposes rescissionA2 moderateSubstance 17/24Owed an answerPosted September 28, 2026 On Regulations.gov

In short: The comment establishes that the agency's alternatives analysis is circular by eliminating protective options based on a deregulation-centered purpose, fails to quantify the degradation of primitive recreation settings and associated economic impacts using data from Table 41, and relies on land management plans that were explicitly acknowledged as lacking specific direction for inventoried roadless areas.

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, Alternative.

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

Governance Policy Process
- “alternatives analysis is built on a circular foundation”
- “purpose and need statement was written to require deregulation”
- “defines away every middle-ground option before analysis begins”
- “plan-reliance rationale that anchors alternatives 2 and 3 is also unsupported”
Recreation Tourism Public Use
- “I camp and hike with my dog”
- “quiet, wildlife-rich camping I value in the Coronado”
- “primitive, semi-primitive non-motorized, or semi-primitive motorized recreation settings”
- “risk of degrading the recreation settings that produce those visits”
Environmental Protection Biodiversity
- “loss of wildlife, waters, and biodiversity”
- “wildflowers, birds, and deer around my campsite”
- “forests and lands, once destroyed, cannot be resurrected”
- “natural circle of life which we humans are a part of”
Legal Regulatory Framework
- “rescission should not be finalized before those updates are either in place or secured by a binding completion schedule”
- “final EIS should identify which specific plan amendments or revisions would be required”
- “alternative that considered maintaining existing inventoried roadless area boundaries”
- “not being responsive to the purpose and need”

What it names

National Forests: Coronado National Forest

The comment

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

I camp and hike with my dog, my friends in the Mount Lemmon area of the Coronado National Forest. I come back with photographs and memories of the wildflowers, birds, and deer around my campsite. These are the places and the moments I am writing to defend, because the proposed rescission of the 2001 Roadless Area Conservation Rule threatens exactly what makes those landscapes worth visiting. The agency's alternatives analysis is built on a circular foundation. The purpose and need statement was written to require deregulation, and then any alternative that keeps meaningful protections in place was eliminated because it failed to satisfy that deregulation-centered purpose. The notice documents this plainly, stating in the Alternatives Considered but Eliminated from Detailed Study section that "An alternative that considered maintaining existing inventoried roadless area boundaries and prohibitions on permanent road construction while allowing temporary road construction and timber harvest was considered but eliminated from detailed study as not being responsive to the purpose and need." That rationale proves nothing. It defines away every middle-ground option before analysis begins. An alternative built around temporary-road-based hazardous fuel treatment and selective harvest inside inventoried roadless areas without permanent road construction could plausibly satisfy the stated fire and forest-health objectives. The agency has not shown otherwise. I ask that the agency explain in the final EIS, in non-circular terms, why such an alternative cannot meet those objectives, and add it to the detailed study range. The recreation impacts of this decision are also inadequately analyzed. The document's own Table 41 shows that "The majority (90 percent) of the potentially affected IRAs are either primitive, semi-primitive non-motorized, or semi-primitive motorized recreation settings." These are the conditions that draw millions of visitors, support local economies, and sustain the kind of quiet, wildlife-rich camping I value in the Coronado. Yet the purpose and need statement does not weigh regulatory relief against the risk of degrading the recreation settings that produce those visits and that spending. The final EIS should analyze how many primitive and semi-primitive acres are projected to shift to roaded or more developed recreation opportunity spectrum classes under each alternative over a 20-year horizon, and should quantify the economic consequences for communities whose livelihoods depend on those settings. The agency should explain how it accounts for those losses. The plan-reliance rationale that anchors alternatives 2 and 3 is also unsupported. The agency acknowledges in the Potentially Affected Environment section that "45 of those were revised between 2001 to 2011 when the status of the Roadless Rule was uncertain due to litigation. Therefore, these plans are less likely to have incorporated IRAs into their management areas or provided specific direction for these areas." The agency simultaneously offers land management plans as the primary safeguard replacing the roadless rule while conceding that most plans were built without adequate inventoried roadless area direction. That is not a safety net. The final EIS should identify which specific plan amendments or revisions would be required to provide equivalent protection in each affected region, and rescission should not be finalized before those updates are either in place or secured by a binding completion schedule. The forests and lands, once destroyed, cannot be resurrected, and the accompanying loss of wildlife, waters, and biodiversity affects the natural circle of life which we humans are a part of. The wildflowers and birds I photograph at Mount Lemmon, and the places like the Grand Canyon, Ironwood Forest Monument, Imperial National Wildlife Refuge, and San Pedro Riparian National Conservation Area that I care about, deserve analysis that looks past short-term regulatory convenience and reckons honestly with what is at stake for future generations.