Comment Analysis · Docket FS-2025-0001

FS-2025-0001-552020

Opposes rescissionA2 moderateSubstance 13/24Owed an answerPosted October 4, 2026 On Regulations.gov

In short: The comment documents that the agency's proposal to rescind the Roadless Rule contradicts its own findings on wildfire risk (citing DEIS Table 21), fails to properly assess economic impacts on specific local businesses by relying on a flawed small-entity certification, and neglects to weigh the reliance interests of stakeholders in the Tonto National Forest.

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
- “I hike and trail run throughout it”
- “quiet backcountry are already under pressure”
- “businesses depend on the quality of the backcountry experience”
- “lost recreation benefit at a minimum of $6.1 million a year”
Water Quality Quantity
- “739 municipal water intakes sit in watersheds containing affected roadless areas”
- “Opening those watersheds to road construction is not an abstraction”
- “people who depend on water flowing out of the Tonto's roadless drainages”
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 DEIS Table 21”
- “far higher fire density on roaded land than inside the affected roadless areas”
Legal Regulatory Framework
- “Ninth Circuit has already reviewed what happens when the national rule is replaced”
- “explain how this proposal avoids the legal deficiencies the court identified”
- “withdraw the small-entity certification and conduct the analysis at the level of the firms”

What it names

National Forests: Tonto National Forest
Roadless areas: Black CrossHorse MesaLime Creek

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 Tonto National Forest is some of my favorite land in Arizona. I hike and trail run throughout it, across places like the Goldfield, Black Cross, Horse Mesa, Boulder, Lime Creek, and Salome roadless areas, and I am filing this comment to oppose the rescission of the 2001 Roadless Area Conservation Rule. What we have is not easily replaced. Once roads go in, the land changes, and that change does not reverse. It is only after we have destroyed so much of the natural beauty of this Earth that we realize what a huge mistake we have made, and there will be no going back. Arizona holds 78 inventoried roadless areas totaling 1,174,256 acres. The areas I named inside the Tonto alone span tens of thousands of acres across a desert landscape where water, wildlife, and quiet backcountry are already under pressure from a growing population. Rescinding the national rule puts all of that at greater risk, and the agency's own record makes the case against doing so. On wildfire, the agency states in its own documents: "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 fuels and fire management grounds. The agency cannot simultaneously hold this finding in its record and use fire as a reason to open roadless areas. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence, and that it reconcile the rescission with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The agency has also tried this before. Its own record reflects that "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 has already reviewed what happens when the national rule is replaced with a state-by-state approach, and the outcome was not favorable to the agency. The Tonto's roadless areas deserve the same protection every comparable forest receives, not a patchwork that varies by political will in any given administration. The agency should address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and explain how this proposal avoids the legal deficiencies the court identified the last time this was attempted. Across the Southwestern region, which includes Arizona, 739 municipal water intakes sit in watersheds containing affected roadless areas. Opening those watersheds to road construction is not an abstraction. The people who depend on water flowing out of the Tonto's roadless drainages have a concrete stake in this rule, and so do the outfitters, guides, and tour operators whose businesses depend on the quality of the backcountry experience those areas provide. Yet the proposal's regulatory flexibility analysis reaches a no-significant-impact conclusion by spreading projected losses across every small firm in the sector nationally, rather than examining the businesses actually holding permits in the affected areas. The agency's own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. That loss does not fall on an abstraction. It falls on specific permit holders operating in specific places. The agency should withdraw the small-entity certification and conduct the analysis at the level of the firms that will actually feel the impact. Finally, the proposal solicits "any reliance interests in the current rule that could be affected by this proposal" and then weighs none of them. This comment is one such interest. People who have planned their recreation, their businesses, and their relationship to public land around the protections the 2001 rule provides deserve more than an open question in the Federal Register. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before it finalizes any action. The Tonto is irreplaceable. Protect it. Sincerely, Caitlin Jahnz Phoenix AZ