Comment Analysis · Docket FS-2025-0001

FS-2025-0001-534139

Opposes rescissionA1 strongSubstance 14/24Owed an answerPosted October 4, 2026 On Regulations.gov

In short: The comment documents that the agency's draft environmental impact statement contains internal contradictions regarding wildfire ignition risks (DEIS Table 21), sediment impacts on water quality, and negative net economic benefits, while failing to identify specific administrative burdens not already addressed by existing regulatory exceptions in 36 C.F.R. Section 294.12.

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
- “get away from roads, away from the noise and hecticness of the city”
- “immerse myself in the fresh air and beauty of these wild lands”
- “recreation losses of at least $6.1 million a year”
Water Quality Quantity
- “roads can produce up to 90 percent of the sediment from a timber sale”
- “affect the watersheds that are the source of drinking water”
- “1,034 municipal water intakes sit in watersheds containing affected roadless areas”
Environmental Protection Biodiversity
- “rare native California species of plants and animals that could never be replaced if lost”
- “A logged stand grows back. A road does not.”
- “My 10-year-old daughter deserves to live on an Earth that has sustainable resources and wildlands”
Governance Policy Process
- “The Forest Service held more than 600 public meetings and took 1.6 million comments to write this rule. It has held none to undo it.”
- “Why have you held no public meetings to see what the citizens of this country think”
- “conduct full public process and substantively address each of these points”

What it names

National Forests: Angeles National Forest
Roadless areas: Arroyo SecoSan Gabriel Add
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 placeEA analysisAnalytical gapEvidenceRequest

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The point of going to the Arroyo Seco, the San Gabriels, or the Sierra Nevada is to get away from roads, away from the noise and hecticness of the city, and to immerse myself in the fresh air and beauty of these wild lands. Rescinding the 2001 Roadless Area Conservation Rule would do exactly what I go there to escape: put roads in. I oppose this proposal, and I ask the agency to respond to the following on the record. The agency's own wildfire analysis undermines the justification for this rescission. Its 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 San Gabriels hold rare native California species of plants and animals that could never be replaced if lost, as I put it, to roads. The agency must explain how it intends to square a wildfire-management rationale for rescission with a finding, from within its own environmental review, that roading these landscapes fivefold increases the human-caused ignition risk. The agency must reconcile the proposal with the ignition data in its own draft environmental impact statement, DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas, and it must do so with specificity, not in general terms. The water issue is just as direct. The agency's own analysis has found that roads can produce up to 90 percent of the sediment from a timber sale, which in turn can affect the watersheds that are the source of drinking water. Water is already scarce, and clean drinking water even scarcer. Across the Pacific Southwest region, which includes California, 1,034 municipal water intakes sit in watersheds containing affected roadless areas. It does not make sense to jeopardize this natural resource, and the agency must explain, with reference to its own sediment and watershed data, how expanding the road system into these areas protects rather than degrades that supply. The economics of this proposal do not hold up. 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." Public lands should be managed for everyone, including future generations, not only for those who want to build roads for their own gain. The agency must reconcile the proposal with its own cost-benefit analysis, which projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million, and it must explain how an action whose own analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog. The rule as written already accommodates the permitting concerns the agency cites. Its own text confirms 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)." California holds 381 inventoried roadless areas totaling 4,389,760 acres. The Arroyo Seco alone covers 4,703 acres of the Angeles National Forest, and the San Gabriel Add covers 2,527 acres of the same forest. These are not abstractions. The agency has not identified which specific administrative burdens are not already addressed by the existing exceptions. It must do so, and must quantify them. My 10-year-old daughter deserves to live on an Earth that has sustainable resources and wildlands. The Forest Service held more than 600 public meetings and took 1.6 million comments to write this rule. It has held none to undo it. Why have you held no public meetings to see what the citizens of this country think of the possibility of rescission? These are the last unroaded third of the national forests. A logged stand grows back. A road does not. The agency must withdraw the rescission proposal or conduct full public process and substantively address each of these points before proceeding further. Sincerely, [Your Name] [Your City, State]