Comment Analysis · Docket FS-2025-0001

FS-2025-0001-548412

Opposes rescissionA1 strongSubstance 17/24Owed an answerPosted October 4, 2026 On Regulations.gov

In short: The comment documents that the agency's proposal to rescind the Roadless Area Conservation Rule contradicts its own DEIS data on fire density and sediment production, fails to quantify administrative burdens outside existing exceptions, ignores the results of the first comment period, and seeks public comment before completing required Tribal consultations and publishing the Tribal Impact Summary Statement.

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

Forest Management Wildfire
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “reconcile the rescission with the ignition data in its own DEIS Table 21”
- “The Eaton Fire turned my skies orange and choked me with smoke”
Water Quality Quantity
- “my drinking water depends on the Angeles”
- “roads and their facilities can produce up to 90 percent of the sediment from a timber sale”
- “1,287 municipal water intakes sit in watersheds containing affected roadless areas”
Recreation Tourism Public Use
- “I go there for peace and quiet, clean air and water, and to escape the crowds”
- “I go there for mental health, an escape, a good view, and to clear my lungs”
- “I would be devastated to lose it”
Tribal Sovereignty
- “viewing the rescission as a threat to inherent rights, Tribal sovereignty, cultural survival”
- “The agency must complete all 64 requested consultations”
- “Tribal governments proposed alternatives... and none was analyzed”

What it names

National Forests: Angeles National Forest
Roadless areas: Strawberry Peak
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 gapEvidenceRequestAlternativeLegal

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Eaton Fire turned my skies orange and choked me with smoke for days. That experience, combined with what the agency's own record shows about fire and roadless areas, is why I am filing this comment opposing the proposed rescission of the 2001 Roadless Area Conservation Rule. I hike and backpack in the Angeles National Forest, especially in the Strawberry Peak area and the San Gabriel Wilderness. I also hike and camp heavily in the Sierra, the Tetons, the Cascades, and the Northern Rockies in Montana. I go there for peace and quiet, clean air and water, and to escape the crowds. As a Pasadena resident, my drinking water depends on the Angeles. Fire has already devastated the Strawberry Peak area, as has drought, and I will be back there this November for a hiking trip. I would be devastated to lose it. I go there for mental health, an escape, a good view, and to clear my lungs. The agency owes me and every other user of these lands a serious accounting of what rescission does to them. On wildfire, 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 nonetheless justifies rescission partly on wildfire and fuels management grounds. That contradiction is not explained anywhere in the rulemaking record. Having watched the Eaton Fire do what it did, I want the agency to explain, in specific terms, why the 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 DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The agency's justification on permitting and administrative burden grounds fares no better against its own text. The rule as written already permits road construction in defined circumstances. The agency's record describes the rule as one that "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 has not identified which specific burdens fall outside those existing exceptions, including those for public health and safety, existing mineral leases, and community wildfire protection. I ask that it do so, with quantification, before any final rule issues. All people deserve clean water, and we know that nature is a key partner in keeping that water clean before it ever enters our municipal systems. The roadless areas feeding the Angeles matter directly to what comes out of my tap in Pasadena. Montana, where I also hike and camp, holds 235 inventoried roadless areas totaling 6,395,392 acres, and 1,287 municipal water intakes sit in watersheds containing affected roadless areas across the Northern region alone. The agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale. The rescission has not grappled with what that means for those intakes or the communities downstream. On public participation, the agency's own count found that over 220,000 comment letters were received, representing over 625,000 submissions, and approximately 99 percent were generally opposed to the rescission, yet the DEIS identifies no issue that changed anything as a result. I commented in that first round and nobody answered me. It is a disgrace. I ask that the agency state plainly which substantive issues from the first comment period altered the proposal, and which were rejected and why. Finally, the agency received 64 requests for Tribal consultation; 29 consultations have been held and 5 more scheduled, with the published Tribal Summary Impact Statement recording that the majority sentiment among consulted Tribal governments is opposition, viewing the rescission as a threat to inherent rights, Tribal sovereignty, cultural survival and the ecological health of ancestral homelands; the final Tribal Impact Summary Statement is deferred to the final rule. That means the public is being asked to comment before the Tribal record is complete. Tribal governments proposed alternatives, including a strengthened roadless rule and a Traditional Homelands Conservation Rule, and none was analyzed. The agency must complete all 64 requested consultations and publish the Tribal Impact Summary Statement for public comment before any final rule is issued. Sincerely, Carson Schubert Pasadena, CA