Comment Analysis · Docket FS-2025-0001

FS-2025-0001-533057

Opposes rescissionA2 moderateSubstance 14/24Owed an answerPosted October 4, 2026 On Regulations.gov

In short: The comment documents that the agency's DEIS and Cost Benefit Analysis fail to quantify the increase in human-caused ignitions from new roads, ignore the $6.9 billion road maintenance backlog in the regulatory flexibility analysis, and omit required reliance interest and protective alternative analyses for specific roadless areas like the Tuolumne River and Black Butte.

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, 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

Recreation Tourism Public Use
- “escape the constant pull in all directions”
- “hike and camp there to experience untouched land”
- “genuinely available to the everyday, average American”
- “lost recreation benefit at a minimum of $6.1 million a year”
Water Quality Quantity
- “1,034 municipal water intakes sitting in watersheds”
- “Opening that country to roads and the extractive activity roads invite”
- “changes the character of places that... remain nearly untouched”
Forest Management Wildfire
- “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”
- “human-caused ignitions increase in abundance with proximity to roads”
- “Rescission means new roads; new roads mean more ignitions”
Economic Impact Fiscal
- “agency is already $6.9 billion behind on road maintenance”
- “does not make sense to build something we will not be able to maintain”
- “certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected”

What it names

National Forests: Los Padres National Forest Stanislaus National Forest
Roadless areas: Black ButteTuolumne River

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The forests around Yosemite and the Stanislaus, including the Tuolumne River roadless area, are where I go to escape the constant pull in all directions that defines everyday life. I hike and camp there to experience untouched land, and the Tuolumne River area, all 17,217 acres of it in the Stanislaus National Forest, is precisely the kind of place the 2001 Roadless Area Conservation Rule was built to protect. I believe it should stay that way, with the Roadless Rule intact. I am filing this comment in opposition to the proposed rescission under Docket FS-2025-0001. California holds 381 inventoried roadless areas totaling 4,389,760 acres, and the Pacific Southwest region, which includes those areas, has 1,034 municipal water intakes sitting in watersheds that contain affected roadless land. Opening that country to roads and the extractive activity roads invite is not a minor administrative adjustment. It changes the character of places that, as I have experienced in the Tuolumne corridor, remain nearly untouched yet accessible in ways that make them genuinely available to the everyday, average American. Our extensive public lands make this country unique and special, and I do not think that value is being given serious weight in this proceeding. On the fire question, the agency's own data makes a case against the proposal it appears to be ignoring. The DEIS states that "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." Rescission means new roads; new roads mean more ignitions; the numbers in the agency's own table show the scale of that increase. I ask that the agency quantify the expected increase in human-caused ignitions that would follow from new road access and weigh that figure openly against whatever wildfire hazard reduction it believes the proposal achieves. The fiscal argument against rescission is equally direct. The agency is already $6.9 billion behind on road maintenance against a budget of roughly $73 million a year. It does not make sense to build something we will not be able to maintain, especially given that we already cannot maintain existing roads appropriately. We should be fiscally responsible and not add to a growing backlog. The regulatory flexibility analysis does not engage this reality honestly. "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 looking at the outfitters and guides who actually hold permits in the affected areas. The agency should withdraw the certification and assess the impact on those specific firms, not the national average. The agency also invited comment on reliance and then performed no analysis of what it received. "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." I have spent time in these areas because the rule existed and the land remained open in the way it did. That is a reliance interest. The agency should identify and weigh the reliance interests described in the comments it receives, including this one, before it proceeds. Finally, the alternatives analysis forecloses the comparison NEPA requires. "Alternatives with more protection were dismissed as not responsive to the deregulatory executive orders, and the keep-boundaries option was cut because it 'would continue to restrict local decision-making discretion' and because analysing roadless values is 'an administrative and legal burden for the agency.'" A purpose defined as deregulation eliminates protective options by definition. The Black Butte roadless area in Los Padres National Forest and the Tuolumne River area in the Stanislaus deserve analysis under at least one alternative that takes their conservation values seriously. The agency should restate the purpose and need in terms of actual forest conditions and carry at least one fully protective alternative through to analysis.