Comment Analysis · Docket FS-2025-0001

FS-2025-0001-552733

Opposes rescissionA2 moderateSubstance 9/24Owed an answerPosted October 5, 2026 On Regulations.gov

In short: The comment documents that the agency's proposed rescission of the 2001 Roadless Area Conservation Rule contains internal contradictions regarding forest health impacts and fails to adequately analyze the long-term, cumulative economic and recreational losses associated with road construction in Cleveland and Inyo National Forests.

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

Recreation Tourism Public Use
- “where I go to get away from roads and buildings”
- “I hike, I camp, I climb there”
- “Once roads go in, that character does not come back”
- “My kids deserve to know these forests the way I do”
Governance Policy Process
- “The agency cannot lean on a forest health rationale while its own findings undercut that rationale”
- “I ask the agency to reconcile these positions squarely”
- “The agency should estimate how cumulative losses to recreation compound over 20 years”
- “without the analysis it requires”
Forest Management Wildfire
- “limited the Forest Service's ability to conduct vegetation management”
- “insect and disease risk in western roadless areas is similar to or lower”
- “explaining how rescission improves forest health”
- “roadless designation does not drive the problem it describes”

What it names

National Forests: Cleveland National Forest Inyo National Forest

The comment

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

The roadless areas of Cleveland National Forest and Inyo National Forest are where I go to get away from roads and buildings. It is my church. I hike, I camp, I climb there, and I want my kids to have this. The proposed rescission of the 2001 Roadless Area Conservation Rule threatens everything those places are. The agency claims in its Rationale for the Proposed Rule that "The 2001 Roadless Rule limited the Forest Service’s ability to conduct vegetation management within inventoried roadless areas and has contributed to the lack of active management of the national forests, which has contributed to challenges in addressing forest health concerns." That assertion is never reconciled with what the agency's own document also finds. The same document acknowledges that the rule did not meaningfully constrain fuel treatments as a share of forested land, and it notes that insect and disease risk in western roadless areas is similar to or lower than on managed forest land. The agency cannot lean on a forest health rationale while its own findings undercut that rationale. I ask the agency to reconcile these positions squarely, explaining how rescission improves forest health when its document's own data suggests roadless designation does not drive the problem it describes. On recreation, the agency offers this figure in its Economic Benefits from Recreation in Roadless Area Forests section: "Assuming an upper limit of a 1 percent annual loss of economic benefit within the likely operable and likely operable but complex areas translates into potential annual losses for trail and dispersed area recreation of $4.8 million and $1.3 million for wildlife-related recreation, nationally." That framing is inadequate. Roads built under a rescinded rule do not disappear after a year. They alter settings permanently. The same section acknowledges that the magnitude of losses is unknown, and it sets that single-year estimate against roadless recreation benefits of upwards of $1.5 billion. I climb and camp in places like the Inyo because the character of the land holds. Once roads go in, that character does not come back. The agency should estimate how cumulative losses to recreation compound over 20 years as roads and settings change, and it should compare that figure honestly against projected timber revenue before finalizing this rule. My kids deserve to know these forests the way I do. This proposed rescission forecloses that without the analysis it requires.