Comment Analysis · Docket FS-2025-0001

FS-2025-0001-546142

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

In short: The comment documents that the agency's proposed rescission of the Roadless Area Conservation Rule fails to reconcile its own cost-benefit data regarding marginal timber gains against significant recreation losses, maintenance backlogs, documented declines in bird abundance, and increased human-caused fire risks in the Arroyo Seco roadless area.

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
- “take my children and sisters to marvel at the outdoors”
- “net negative to the quality of life for people in this urban area”
- “recreation losses of at least $6.1 million a year”
- “outfitters, guides and tour operators as affected”
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”
- “documented biological cost”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent”
- “Forest Service carries a $6.9 billion maintenance backlog”
- “net present value spanning negative $92 million to positive $199 million”
- “livelihoods depend on the character of these landscapes”
Forest Management Wildfire
- “Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land”
- “human-caused ignitions increase in abundance with proximity to roads”
- “building roads into the Arroyo Seco... carries a calculable human-caused fire risk”
- “wildfire is already the defining land-management challenge”

What it names

National Forests: Angeles National Forest
Roadless areas: Arroyo Seco
Works cited: Kroeger et al. 2022

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 Eastern Sierras are where I take my children and sisters to marvel at the outdoors, and the Arroyo Seco roadless area in the Angeles National Forest is the kind of place that makes that possible for the residents of Los Angeles County. Opening it up to roads and logging would be a net negative to the quality of life for people in this urban area, and I am filing this comment in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001. The stated economic rationale does not survive contact with the agency's own numbers. The record before the agency states that "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." These are marginal figures. The agency's own Cost Benefit Analysis 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 negative $92 million to positive $199 million, a range so wide it cannot establish a net benefit. Meanwhile the Forest Service carries a $6.9 billion maintenance backlog on the road system it already has. I ask that the agency reconcile this proposal with those figures and explain how expanding a road network it cannot afford to maintain is justified when its own analysis cannot demonstrate a positive return. The small-business certification accompanying this proposal is contradicted by the analysis sitting beside it. "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." 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 businesses that hold permits in and around areas like Arroyo Seco are not the national average firm; they are small, place-specific operations whose livelihoods depend on the character of these landscapes. The agency reached its no-impact conclusion by spreading losses across every small firm in the sector nationally rather than examining the permits actually at stake. I ask that the agency withdraw the certification and conduct an assessment of the small entities actually operating in the potentially affected roadless areas. I love seeing new birds, even when I cannot name the species. That experience depends on something the agency's own record documents. The DEIS cites 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. (source: DEIS; Kroeger et al. 2022; McClure et al. 2013; Ware et al.) Arroyo Seco offers that quiet to the people of Los Angeles County precisely because it remains unroaded. The agency has not explained how it weighs this documented biological cost against the marginal economic gains it projects. The agency must answer that question directly. The proposal also 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. I have brought my children and sisters into these landscapes under the expectation that what Teddy Roosevelt fought for over a century ago would remain protected. People plan trips, choose where to live, build businesses, and raise families around these landscapes. The agency is legally required to identify and weigh the reliance interests its prior policy created, and I ask that it do so with respect to the comments it receives, including this one. Finally, the agency's own fire data undercuts a central premise of the rescission. "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." In a state where wildfire is already the defining land-management challenge, building roads into the Arroyo Seco and places like it carries a calculable human-caused fire risk that the agency has not quantified. I ask that the agency produce that quantification and weigh it against whatever wildfire-hazard reduction it claims to anticipate. Sincerely, Cassia Roth Claremont, CA