Comment Analysis · Docket FS-2025-0001

FS-2025-0001-495506

Opposes rescissionA2 moderateSubstance 14/24Owed an answerPosted September 28, 2026 On Regulations.gov

In short: The comment establishes that the agency's DEIS data contradicts the fire safety rationale for rescission by showing higher ignition rates on roaded lands, and documents specific deficiencies in the small business certification and reliance interest analysis regarding local outfitters and recreation users in the Sequoia National Forest.

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
- “Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires”
- “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”
- “fire risk that the agency's own numbers show increases with road access”
Recreation Tourism Public Use
- “I go to places like Mill Creek in Sequoia National Forest in California to experience the landscape, get exercise, and connect with the natural world”
- “I photograph wildlife, sunsets, and rivers”
- “lost recreation benefit at a minimum of $6.1 million a year”
- “outfitters, guides and tour operators as affected”
Water Quality Quantity
- “1,034 municipal water intakes sit in watersheds containing affected roadless areas”
- “businesses tied to clean water”
- “water supply values touching more than a thousand municipal intakes in this region alone”
Governance Policy Process
- “The agency must explain, in quantitative terms, how it weighs an expected increase in human-caused ignitions”
- “The agency must withdraw the small-business certification and replace it with an analysis of the specific firms”
- “An agency changing course is required to identify and weigh the reliance interests its prior policy created”

What it names

National Forests: Sequoia National Forest
Roadless areas: Mill Creek

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequest

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The outdoors is worth protecting for its own sake. I go to places like Mill Creek in Sequoia National Forest in California to experience the landscape, get exercise, and connect with the natural world. I photograph wildlife, sunsets, and rivers. What I find there is not a commodity to be extracted but a common good to be kept whole. The proposed rescission of the 2001 Roadless Area Conservation Rule threatens that, and this letter explains why the agency has not made an adequate case for it. The fire argument the agency offers cuts directly against the proposal. The agency's own 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 DEIS makes this precise: "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." I photograph and hike in these places. The wildlife I go looking for, the rivers I frame in a viewfinder, the landscape I move through for exercise, all of it is subject to fire risk that the agency's own numbers show increases with road access. The agency must explain, in quantitative terms, how it weighs an expected increase in human-caused ignitions against whatever hazard reduction it claims road access would produce, and it must do so before any final rule issues. The economic certification does not hold up. The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. That certification is reached by spreading losses across every small firm in the sector nationally rather than examining the outfitters and guides who actually hold permits in the affected areas. California alone holds 381 inventoried roadless areas totaling 4,389,760 acres, and across the Pacific Southwest region 1,034 municipal water intakes sit in watersheds containing affected roadless areas. The businesses tied to clean water, wildlife habitat, and undeveloped scenery in places like Mill Creek are not a national average. The agency must withdraw the small-business certification and replace it with an analysis of the specific firms operating under permit in the potentially affected roadless areas. On reliance, the agency's own notice makes the problem plain. The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. This comment is exactly the kind of reliance interest the notice invites. I plan my recreation, my photography, and my connection to public land around the expectation that inventoried roadless areas remain protected. An agency changing course is required to identify and weigh the reliance interests its prior policy created, not simply collect them and set them aside. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, and must explain what weight they received in the final decision. Public land exists for the common good and to protect nature. That is not a sentimental position. It is reflected in the agency's own data, which show dramatically lower fire ignition rates inside roadless areas, recreation benefits the Cost Benefit Analysis itself quantifies, and water supply values touching more than a thousand municipal intakes in this region alone. The case for rescission rests on fire management rationale that the agency's own DEIS contradicts, a small-business finding that examines the wrong population, and a reliance inquiry the Cost Benefit Analysis never completes. None of that meets the standard required for a reasoned change of course. Sincerely, Sarah Timberman Los Angeles, CA