Comment Analysis · Docket FS-2025-0001

FS-2025-0001-529101

Opposes rescissionA1 strongSubstance 16/24Owed an answerPosted October 1, 2026 On Regulations.gov

In short: The comment documents that the agency's proposal to rescind the Roadless Area Conservation Rule fails to reconcile its own DEIS data on wildfire incidence and its Cost Benefit Analysis on net economic benefits, and that the small-business certification is unsupported by local data for Prescott, Arizona.

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, Evidence, 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

Recreation Tourism Public Use
- “quiet, secluded areas of northern Arizona are where I take my kids”
- “hike and camp across this part of the state specifically because those unroaded places still exist”
- “places where they can escape the busy world and encounter nature that has not been carved up”
- “recreation losses of at least $6.1 million a year”
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”
- “fire danger increases as vehicles travel further in”
- “reconcile the rescission with the ignition data in its own DEIS”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “road maintenance backlog of $6.9 billion already sitting on the books”
- “net present value ranging from -$92 million to +$199 million”
- “small-business certification accompanying this proposal is similarly unsupported”
Water Quality Quantity
- “739 municipal water intakes sit in watersheds containing affected roadless areas”
- “communities and businesses that depend on those watersheds are not a national average”
- “waters and the land around them carry the character they carry precisely because roads have not been pushed into every corner”

What it names

National Forests: Prescott National Forest
Law cited: 36 C.F.R. Section 294.12

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The quiet, secluded areas of northern Arizona are where I take my kids. That is what I am fighting to protect. Arizona holds 78 inventoried roadless areas totaling 1,174,256 acres, and I hike and camp across this part of the state specifically because those unroaded places still exist. Two of the lakes where I paddle near Prescott are managed by the Prescott National Forest, and those waters and the land around them carry the character they carry precisely because roads have not been pushed into every corner. There is already enough infrastructure in Arizona. What I want for my children are places where they can escape the busy world and encounter nature that has not been carved up. Being outside is proven to be good for mental health, and this rescission would only reduce the opportunities to enjoy the outdoors. That is not a speculative harm. It is the direct and predictable result of the action being proposed. The agency's own record makes the wildfire case against rescission, not for it. 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." I have watched what happens in and around the Prescott National Forest when access expands. People use roads to camp illegally, fire danger increases as vehicles travel further in, and untouched land disappears. The agency must explain, in specific terms, why this proposal departs from its own prior findings on fire occurrence, and it must reconcile the rescission with the ignition data in its own DEIS, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic rationale is no stronger. The agency's own record states: "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." Against that, 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, a net present value ranging from -$92 million to +$199 million, and a road maintenance backlog of $6.9 billion already sitting on the books. The agency must reconcile the proposal with that analysis and explain on the record how expanding a road system already burdened by that deficit serves the public interest when its own numbers cannot establish a net benefit. The proposal also overstates the regulatory problem the rescission is meant to solve. The rule as written states that it "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. Section 294.12(b)(1),(3)." The agency has not identified which specific permitting or administrative burdens fall outside those existing exceptions, including those covering public health and safety, existing mineral leases, and community wildfire protection. I ask that it do so, with specifics, rather than rescinding a rule built over more than 600 public meetings and 1.6 million comments on the basis of burdens it has not quantified. The small-business certification accompanying this proposal is similarly unsupported. The agency certifies no significant impact on small entities while its own 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 conclusion is reached by spreading an expenditure loss across every small firm in the sector nationally rather than examining the outfitters and guides actually holding permits in the affected areas. Across the Southwestern region alone, 739 municipal water intakes sit in watersheds containing affected roadless areas, and the communities and businesses that depend on those watersheds are not a national average. The agency should withdraw the certification and assess the impact on the small entities actually operating in these places. My children deserve to inherit at least as much unroaded country as I found. The agency has offered no record-based reason why they should not. Sincerely, Sara Sexson Prescott, Arizona