Comment Analysis · Docket FS-2025-0001

FS-2025-0001-524511

Opposes rescissionA1 strongSubstance 12/24Owed an answerPosted October 1, 2026 On Regulations.gov

In short: The comment documents that the agency's proposal to rescind the Roadless Rule conflicts with its own draft EIS data on wildfire ignition rates and cost-benefit analyses regarding road maintenance backlogs and net economic value, while citing prior court holdings that the 2001 rule was within statutory authority.

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, 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

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 wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “reports 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”
- “net present value spanning -$92 million to +$199 million”
- “existing road system already carries a $6.9 billion maintenance backlog”
Legal Regulatory Framework
- “Ninth Circuit found deficiencies in it”
- “Tenth Circuit held... REVERSE the district court's order”
- “found the 2001 rule was within the authority Congress granted under the Organic Act”
Recreation Tourism Public Use
- “where I hike every weekend”
- “where I go to camp”
- “recreation losses of at least $6.1 million a year”

What it names

National Forests: Angeles National Forest Inyo National Forest San Bernardino National Forest
Law cited: 28 U.S.C. Section 1291

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 Angeles National Forest is where I hike every weekend. The Inyo National Forest is where I go to camp. The San Bernardino National Forest is where I photograph blooms, the change of seasons, and wildlife. These places are part of how I live, and I am opposing the rescission of the 2001 Roadless Area Conservation Rule. The strongest argument against this rescission comes from the agency's own words on fire. The proposal uses wildfire management as a justification for opening roadless areas to roads, but the agency's record states plainly: "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." I hike in the Angeles National Forest, which sits in a region of serious and ongoing fire risk. The agency must explain why this proposal departs from that finding, 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 economic case for rescission is not established by the agency's own numbers. The record shows 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 to the Forest Service against recreation losses of at least $6.1 million a year, with a net present value spanning -$92 million to +$199 million. That range cannot establish a net benefit. I have come across many roads and campsites that are not maintained, and the existing road system already carries a $6.9 billion maintenance backlog against a road budget of about $73 million a year. We should be maintaining what already exists. The agency must reconcile this proposal with its own analysis and explain how expanding a road system carrying that backlog is justified when the economic outcome is, by its own accounting, uncertain at best. The state-by-state approach this proposal advances has a legal history the agency must address. The record includes the agency's own prior statement 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." That approach was challenged, and the Ninth Circuit found deficiencies in it. The agency must address its own prior finding that local decision-making can incrementally reduce nationally significant roadless values, and explain how this proposal avoids repeating those deficiencies. On the question of statutory authority, the courts have already spoken. The Tenth Circuit held, reversing a district court injunction against the rule: "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 must explain the basis for any position contrary to that holding. Our public lands should be protected and their ecosystems preserved for wildlife and recreation. The Angeles, the San Bernardino, and the Inyo are places I rely on. This proposal does not hold up against the agency's own record, and I ask that the comments above be answered specifically and in writing before any final action is taken. Sincerely, Ashley Los Angeles, CA