Comment Analysis · Docket FS-2025-0001

FS-2025-0001-536349

Opposes rescissionA1 strongSubstance 16/24Owed an answerPosted October 4, 2026 On Regulations.gov

In short: The comment establishes that the proposed rescission of the Roadless Area Conservation Rule contradicts the agency's own findings regarding wildfire ignition rates on roaded lands, fails to reconcile economic projections showing potential net losses with the justification for road expansion, and ignores the impact on 1,034 municipal water intakes in the Pacific Southwest.

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

Water Quality Quantity
- “1,034 municipal water intakes sit in watersheds containing affected roadless areas”
- “Road construction impairs streams and watersheds and reduces the availability of clean water”
- “roads and their facilities can produce up to 90 percent of the sediment from a timber sale”
Forest Management Wildfire
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires”
- “reconcile the rescission with the ignition data in its own draft environmental impact statement”
Recreation Tourism Public Use
- “I go to the National Parks and Forests to hike, mountain bike, road ride, and carry a camera”
- “Public lands should be managed for recreation, not commercial development”
- “recreation losses of at least $6.1 million a year”
Wildlife Habitat
- “The wildlife was uprooted, and initially, the only surviving creatures were rats”
- “Many endangered species would become extinct if their habitat is destroyed”
- “The wildlife, the water, and the trails I photograph and ride depend on this rule standing”

What it names

National Forests: Cleveland National Forest
Roadless areas: Ladd
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 gapEvidenceRequest

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I go to the National Parks and Forests to hike, mountain bike, road ride, and carry a camera because the beauty is unparalleled. These rides and walks are some of my most treasured memories. The Cleveland National Forest has been my backyard for 10 years, and I am writing to oppose the rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001. The Cleveland National Forest is my backyard in a literal sense. I have endured 2 wildfires and, as a result, a flash flood. My neighbors have lost homes. The wildlife was uprooted, and initially, the only surviving creatures were rats. Slowly the rest of the wildlife has returned. I say this because 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 before the agency justifies rescission in part on wildfire and fuels management grounds. That justification moves in the opposite direction from the agency's own finding. 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 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. The Ladd roadless area in Cleveland National Forest covers 5,300 acres. California holds 381 inventoried roadless areas totaling 4,389,760 acres. Across the Pacific Southwest region, 1,034 municipal water intakes sit in watersheds containing affected roadless areas. The undeveloped public lands provide clean drinking water for Americans and for the wildlife that inhabit them. Road construction impairs streams and watersheds and reduces the availability of clean water for millions of people. The agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale. The agency needs to explain, specifically and on the record, how rescission of the rule is consistent with protecting those 1,034 municipal water intakes in the Pacific Southwest and the streams that feed them. The proposal also justifies rescission on timber economics and employment grounds. 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." I ask that the agency reconcile the proposal with its own economic analysis, which 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 and a net present value spanning -$92 million to +$199 million, and that it explain on the record how an action whose own Cost Benefit Analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog. Building new roads is clearly not sensible given the current budgeting problems. The proposal argues that state-specific approaches can replace one national rule. The agency's own record states: "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The Ninth Circuit reviewed that state-by-state approach. The agency must address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and explain how this proposal avoids the deficiencies the Ninth Circuit identified the last time the agency replaced the national rule with a state-by-state approach. Finally, the proposal cites permitting burdens and administrative costs as grounds for rescission. The rule as written, by the agency's own account, "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 should identify which specific burdens are not already addressed by those existing exceptions, including those for public health and safety, existing mineral leases, and community wildfire protection, and should quantify those burdens with specificity. Public lands should be managed for recreation, not commercial development. Many endangered species would become extinct if their habitat is destroyed, because their future is already precarious. The wildlife, the water, and the trails I photograph and ride depend on this rule standing. Sincerely, Jill Hitchcock Silverado, CA 92676