Comment Analysis · Docket FS-2025-0001

FS-2025-0001-527495

Opposes rescissionA2 moderateSubstance 13/24Owed an answerPosted October 1, 2026 On Regulations.gov

In short: The comment documents that the proposed rescission of the Roadless Area Conservation Rule contradicts the agency's own DEIS data regarding wildfire ignition densities and sediment production, fails to properly assess reliance interests and small entity impacts, and threatens specific watersheds and recreation areas in Southern California.

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
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “ignition density of 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas”
- “A road does not, and neither does a forest burned more frequently because a road made it accessible”
Water Quality Quantity
- “I drink water that comes directly from Southern California rivers and aquifers”
- “roads and their facilities can produce up to 90 percent of the sediment from a timber sale”
- “fewer than 12 percent of the watersheds fed by roadless areas have impaired streams today”
Recreation Tourism Public Use
- “I go for the quiet, the dark starry skies, and the chance to be active in nature”
- “lost recreation benefit of at minimum $6.1 million a year”
- “Outfitters, guides, and tour operators who hold permits in the affected areas depend on the conditions the Roadless Rule maintains”
Governance Policy Process
- “bypasses the public process that created the rule”
- “The Forest Service held more than 600 public meetings and received 1.6 million comments to write this rule. It has held none to undo it.”
- “An agency changing course is required to assess the reliance its prior policy created”

What it names

National Forests: Cleveland National Forest

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 Santa Ana, San Gabriel, and San Bernardino Mountains are where I hike and camp. I go for the quiet, the dark starry skies, and the chance to be active in nature. I ride trails in the Santa Ana and San Jacinto mountains and through the Cleveland and San Bernardino National Forests. I paddle wherever I can reach within a day's drive, particularly the coast and lakes in the Sierra Nevada. I am writing to oppose Docket FS-2025-0001, the proposed rescission of the 2001 Roadless Area Conservation Rule, on the grounds that it contradicts the agency's own data, bypasses the public process that created the rule, and threatens the forests and watersheds that millions of Americans, including me, depend on. The edges of the Cleveland National Forest and many other forests are already threatened by roads and development. I see no reason to make that situation worse by opening the last unroaded portions of these landscapes to further incursion. 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 proposal justifies rescission partly on wildfire and fuels management grounds, yet the agency's own DEIS reports ignition density of 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas, and states that human-caused ignitions increase in abundance with proximity to roads. The agency must explain why the proposal departs from these findings and reconcile the rescission with the ignition data in DEIS Table 21, which shows far higher fire density on roaded land than inside the affected roadless areas. I drink water that comes directly from Southern California rivers and aquifers, and extractive activities threaten those sources and imperil both human and non-human life in the region. The Cleveland and San Bernardino National Forests sit within watersheds that feed communities across Southern California. The agency's prior analysis found that roads and their facilities can produce up to 90 percent of the sediment from a timber sale, and that fewer than 12 percent of the watersheds fed by roadless areas have impaired streams today. That is not a problem to manufacture. The agency must answer how it weighs the sediment and contamination risk to these municipal water sources against whatever benefit it claims from rescission. The agency's own cost-benefit analysis records a lost recreation benefit of at minimum $6.1 million a year. I participate in rock climbing and off-highway vehicle use, and I have studied how those user communities have built working partnerships with conservation agencies, the BLM, and national park rangers, through organizations like the Access Fund and Tread Lightly, to protect California's inland deserts and forests. Outfitters, guides, and tour operators who hold permits in the affected areas depend on the conditions the Roadless Rule maintains. The agency certifies no significant impact on small entities while naming those very businesses as affected. That certification was reached by spreading the expenditure loss across every small firm in the sector nationally rather than assessing the permit holders actually operating in the affected areas. The agency must withdraw that certification and conduct an honest assessment of the small entities whose livelihoods are directly at stake. On the question of reliance: the Forest Service held more than 600 public meetings and received 1.6 million comments to write this rule. It has held none to undo it. I have taught my children to love and respect our public wildlands, and our family is among the millions of Americans who have structured their relationship to these places under the assurance the Roadless Rule provided. The agency's own 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. That is not a minor procedural gap. An agency changing course is required to assess the reliance its prior policy created. This comment is one such interest. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. Finally, the agency must quantify the expected increase in human-caused ignitions from new road access in the affected roadless areas and weigh that figure against whatever reduction in wildfire hazard it claims. The data in its own DEIS makes that comparison necessary. A logged stand grows back. A road does not, and neither does a forest burned more frequently because a road made it accessible. Sincerely, Juliann Emmons Allison Riverside, CA