Comment Analysis · Docket FS-2025-0001

FS-2025-0001-552221

Supports rescissionA2 moderateSubstance 10/24Owed an answerPosted October 4, 2026 On Regulations.gov

In short: The comment documents that the Roadless Rule's prohibition on active management hinders necessary wildfire risk mitigation through thinning in Northern California and Southern Oregon, and identifies specific analytical flaws in the agency's reliance on road-proximity fire ignition statistics.

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.

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
- “disastrous wildfires are becoming larger and more frequent”
- “Thinning of smaller trees... is an important tool to make the forest more resilient”
- “designation of roadless has been a lawsuit magnet preventing active management”
- “ignitions need to be evaluated together with ease of suppression access”
Legal Regulatory Framework
- “It is basically an executive order, which was contrary to the intent of congress”
- “makes a broad-brush general decision which is not always in the public interest”
- “subject to the requirements of the Endangered Species Act, the Clean Water Act, the NEPA Act”
- “boundaries were practically impossible to change”
Water Quality Quantity
- “Water quality and fish protection is not a real issue in this decision”
- “locating roads where they will not adversely affect streams”
- “using skyline techniques on steeper slopes which minimize soil disturbance”
- “respecting the riparian reserves established in the Northwest Forest Plan”

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequestAlternativeLegal

I would like to comment on the proposed repeal of the Roadless Rule for National Forests. I am a USFS retiree with a good familiarity with the forests in Northen California and Southern Oregon. I worked in planning for timber harvest and other uses, and was also a fire fighter when extra help was needed. I like to hike and fish in national forests. If you are just putting all of these letters in two piles, I will start by saying the roadless rule should definitely be repealed. It is basically an executive order, which was contrary to the intent of congress, and makes a broad-brush general decision which is not always in the public interest. The roadless areas in question are for the most part lands which were released for multiple use management in the various state wilderness Acts. The release language does not mandate that each roadless area be managed for timber production, but it does direct the USFS to look at each roadless area individually and make a case-by-case decision on how to manage it in the public interest. Any proposals to actively manage roadless areas would still be subject to the requirements of the Endangered Species Act, the Clean Water Act, the NEPA Act, and the National Forest Management Act of 1976. The repeal of the roadless rule would not mean that all or a majority of the roadless areas would be roaded and logged or mined. In the forests I am most familiar with, during the time period after the Northwest Forest Plan but before the roadless rule, about 80% of the released roadless areas were put into a land allocation that basically called for preservation, such as late successional reserve or semi-primitive recreational use. The 80% might have been available for some form of thinning or fire salvage, but were always the lowest priority. Some of the inventoried roadless areas are not really roadless, either because old roads were left out of the inventory or because they were roaded in the interval between the California Wilderness Act and the listing of the Northern Spotted Owl. However, once the roadless rule was finalized, it seemed that the boundaries were practically impossible to change. As the climate changes, disastrous wildfires are becoming larger and more frequent, especially in the west. Thinning of smaller trees, with removal of usable wood and disposal by piling and winter burning of the unusable slash, is an important tool to make the forest more resilient, leaving a stand consisting of the more fire-resistant species and the healthiest trees, at a spacing which is dense enough to allow canopy closure within 15 years, but open enough to allow the development of a good root system for better drought resistance, and thicker, more fire resistant bark This treatment can not be done economically more than a quarter mile from a road, In theory, section 294.13b of the roadless rule allows commercial thinning which would remove usable wood to reduce the cost of the fuels reduction. But in practice, the designation of roadless has been a lawsuit magnet preventing active management. The oft repeated argument that approximately 80% of all man caused fire ignitions occur close to a road is a very flawed analysis, for several reasons. First, it does not break it down by type of road. The roads going through national forests include state highways with a traffic of thousands of vehicles daily, county roads which might see over 100 vehicles per day, and main forest service roads which would see dozens per day. A single lane, unpaved road in a former roadless area, in contrast, would probably see only a few vehicles per week, and might well be gated or otherwise closed during high fire season. On which roads are fires more likely to occur? The second flaw is that the study ignores lightning fires. In a typical year, lightning may cause only 10% of the ignitions, but some of the worst fire seasons in recent history have been caused by late summer dry lightning storms up and down the state of California, which ignited hundreds of fires at once. These dry lightning storms seem to be getting more common, which could be an effect of climate change. The location of lightning strikes is pretty random. I don’t know whether anyone has studied the distribution of lightning strikes, but I suspect that, if anything, they would be concentrated in higher elevation areas that are more likely to be unroaded. The third flaw is that ignitions need to be evaluated together with ease of suppression access, rate of fire spread and resistance to control. Water quality and fish protection is not a real issue in this decision. The forest service has a good record in the past 30 years of locating roads where they will not adversely affect streams, and using skyline techniques on steeper slopes which minimize soil disturbance, as well as respecting the riparian reserves established in the Northwest Forest Plan.