Comment Analysis · Docket FS-2025-0001

FS-2025-0001-535331

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

In short: The comment documents that the agency's own DEIS data (Table 21) contradicts the wildfire rationale for rescinding the Roadless Rule by showing higher fire density on roaded lands, and asserts a specific reliance interest in the stability of the 2001 Rule for recreation in Angeles National Forest.

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
    • “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 than on essentially unroaded lands”
    • “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”
  • Recreation Tourism Public Use
    • “The trails I walk in Angeles National Forest... give me what I need most: a chance to recharge”
    • “I take nothing out but photos and memories”
    • “I plan my travels, choose my destinations, and build my life around the expectation that these forests remain intact”
  • Governance Policy Process
    • “The agency invited reliance interests and then did nothing with them”
    • “I ask the agency to quantify the expected increase in human-caused ignitions”
    • “I ask the agency to explain why this proposal departs from its own prior findings”

What it names

National Forests
Angeles National Forest
Roadless areas
Arroyo Seco

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 trails I walk in Angeles National Forest, along Arroyo Seco and across this country, give me what I need most: a chance to recharge, to get inspired, and to reconnect to what matters. I take nothing out but photos and memories. I am writing because the proposal to rescind the 2001 Roadless Area Conservation Rule would put that at risk, and because the agency's own documents make the case against it better than I can. The fire argument troubles me most. I live with the aftermath of the Eaton and the Palisades fires… The agency justified this rescission in part on wildfire and fuels management grounds, but its own record says: "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." That finding does not support opening roadless areas; it argues the opposite. The agency's own data reinforce this: "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." That is not a narrow gap. I ask the agency to quantify the expected increase in human-caused ignitions that would follow from new road access and to weigh that increase honestly against whatever reduction in wildfire hazard is claimed. The wildfire rationale cannot stand on one side of the ledger only. I ask the agency to explain why this proposal departs from its own prior findings on fire occurrence in roadless areas, and to reconcile the rescission with the ignition figures its own DEIS Table 21 reports, which show fire density on roaded land vastly exceeding that inside the affected roadless areas. Finally, the agency invited reliance interests and then did nothing with them. 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. This comment is a reliance interest. I plan my travels, choose my destinations, and build my life around the expectation that these forests remain intact. I believe, as a matter of principle, that public lands should be managed for seven generations forward, because we are only stewards. That belief rests on rules that hold. When an agency changes course, it owes the public an accounting of what those who relied on the prior policy now stand to lose. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one. The 2001 rule has shaped how millions of people relate to these forests. Angeles National Forest, the Arroyo Seco corridor, and wild places across this country carry value that compound interest cannot measure. The agency must account for what it proposes to undo. Sincerely, Irina Tehrani Marina del Rey, California

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