Comment Analysis · Docket FS-2025-0001

FS-2025-0001-550275

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

In short: The comment documents that the DEIS data (Table 21) contradicts the fire justification for rescission, identifies specific water quality risks to 1,034 municipal intakes in the Pacific Southwest, challenges the credibility of the regulatory flexibility analysis regarding small entities, and asserts a specific reliance interest in the 2001 Roadless Rule protections.

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
- “The fire justification for rescission does not survive a reading of the DEIS”
- “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”
Water Quality Quantity
- “1,034 municipal water intakes sit in watersheds containing affected roadless areas”
- “Road construction in areas like the Tuolumne River watershed carries direct consequences for water quality downstream”
- “opening these watersheds to road building means for the communities and intakes that depend on them”
Recreation Tourism Public Use
- “The Sierra Nevada range... is where I climb”
- “I have planned my use of these lands around the protections the 2001 rule provides”
- “lost recreation benefit at a minimum of $6.1 million a year”
Legal Regulatory Framework
- “The regulatory flexibility analysis is not credible”
- “Under the legal standards that govern agency reversals, that kind of reliance interest must be identified and weighed”
- “The agency should withdraw the certification and conduct an analysis focused on the small entities actually operating in the potentially affected roadless areas”

What it names

National Forests: Stanislaus National Forest
Roadless areas: Tuolumne River

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 Sierra Nevada range, from Lake Tahoe down through the Stanislaus and on to Bishop, is where I climb. The country I move through includes the Tuolumne River roadless area, 17,217 acres inside the Stanislaus National Forest. I am filing this comment to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001. My view of what public land should be managed for is straightforward: environmental restoration and preservation. This proposal moves in the opposite direction, and the agency's own record explains why. The fire justification for rescission does not survive a reading of the DEIS. 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 Tuolumne River area and the broader Tahoe region are exactly the kind of high-elevation, fire-prone landscapes this finding describes. I ask that the agency explain why the proposal departs from these prior findings and reconcile the rescission with DEIS Table 21, which reports 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 across the decade 2014 to 2024. The DEIS itself states that human-caused ignitions increase in abundance with proximity to roads. The agency should quantify the expected increase in ignitions from new road access and weigh it against any claimed reduction in wildfire hazard before this rule proceeds. 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. Road construction in areas like the Tuolumne River watershed carries direct consequences for water quality downstream. The agency has not adequately addressed what opening these watersheds to road building means for the communities and intakes that depend on them. That question deserves a direct answer in the record. The regulatory flexibility analysis is not credible. 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 losses across every small firm in the sector nationally rather than examining the outfitters and guides who actually hold permits in the affected areas. Spreading a known loss across a national average firm does not assess whether the firms in these specific places are harmed. The agency should withdraw the certification and conduct an analysis focused on the small entities actually operating in the potentially affected roadless areas. Finally, the agency invites comment on reliance while never weighing it. 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. I have planned my use of these lands around the protections the 2001 rule provides. Under the legal standards that govern agency reversals, that kind of reliance interest must be identified and weighed, not solicited and ignored. This comment is such an interest. The agency must account for the reliance interests described in the record it is building, including this one. Sincerely, Joshua Thomas Daly City CA