Comment Analysis · Docket FS-2025-0001

FS-2025-0001-539755

Opposes rescissionA2 moderateSubstance 15/24Owed an answerPosted October 4, 2026 On Regulations.gov

In short: The comment documents specific deficiencies in the agency's analysis regarding bird abundance, wildfire ignition densities, road maintenance backlogs, small entity impacts, and reliance interests, citing specific data from the DEIS and requesting on-record explanations and mitigation measures.

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

Recreation Tourism Public Use
- “The quiet is what I go for: the birds singing, water moving, twigs breaking underfoot”
- “I hike and camp to hear those things, and I kayak on lakes because the stillness is grounding”
- “I have paddled Loon Lake in the Rubicon roadless area... struck by how few other people were on the water”
- “I have backpacked Black Butte... drawn by its vistas and by the distance it puts between me and human-made noise”
Wildlife Habitat
- “bird richness declines with road presence in forested habitat”
- “road-noise experiments in a roadless area cut bird abundance by over a quarter”
- “31 percent of species avoiding the noise entirely”
- “quiet that sustains abundance. Roads end that”
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”
- “human-caused ignition density of 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas”
- “The agency must quantify the expected increase in human-caused ignitions that new road access would bring”
Water Quality Quantity
- “1,034 municipal water intakes sit in watersheds containing affected roadless areas”
- “The drinking water consequences of rescission for California communities are documented”
- “deserve a direct response, not a general assurance”

What it names

National Forests: Eldorado National Forest Los Padres National Forest
Roadless areas: Black ButteRubicon

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 quiet is what I go for: the birds singing, water moving, twigs breaking underfoot. I hike and camp to hear those things, and I kayak on lakes because the stillness is grounding in a way that nothing else is. I have paddled Loon Lake in the Rubicon roadless area of Eldorado National Forest, where my fiancee's family has a tradition of going every year, and I was struck by how few other people were on the water. I have backpacked Black Butte in Los Padres National Forest with friends, drawn by its vistas and by the distance it puts between me and human-made noise. Both of those places exist because a rule has protected them. This comment opposes the rescission of that rule. The birds I listen for are not incidental to this argument. The agency's own draft environmental impact statement acknowledges the findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. Rubicon and Black Butte hold what those experiments measured: quiet that sustains abundance. Roads end that. I ask the agency to explain, specifically and on the record, how rescission can be squared with the bird abundance and richness findings its own DEIS cites, and what mitigation, if any, it proposes for the forested roadless habitat those species require. On wildfire, the agency's own text 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 offers wildfire and fuels management as a justification for rescission while its own record reports a human-caused ignition density of 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas, figures drawn from DEIS Table 21 covering 2014 through 2024. The DEIS further states that human-caused ignitions increase in abundance with proximity to roads. The agency must quantify the expected increase in human-caused ignitions that new road access would bring and weigh that figure against whatever reduction in wildfire hazard it claims to achieve. The road maintenance numbers make the proposal harder still to defend. The agency carries a backlog measured in billions against an annual road budget of roughly $73 million. It is illogical to push road construction into country that has none when the roads already built cannot be maintained on current funding. I agree with that logic, and I ask the agency to explain why it does not. California holds 381 inventoried roadless areas totaling 4,389,760 acres, and across the Pacific Southwest region 1,034 municipal water intakes sit in watersheds containing affected roadless areas. The drinking water consequences of rescission for California communities are documented in the agency's own analysis and deserve a direct response, not a general assurance. 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 expenditure losses across every small firm in the sector nationally rather than examining the outfitters and guides actually holding permits in the affected areas. The agency should withdraw that certification and assess the impact on the firms that will actually feel it. Finally: 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 one such interest. The traditions built around Loon Lake, the trips to Black Butte, the expectation that these areas would remain unroaded because a rule said so, are exactly what an agency changing course is required to identify and weigh. The agency must account for the reliance interests described in the comments it receives, including this one. Sincerely, Maija Wigoda-Mikkila Pacifica, CA