Comment Analysis · Docket FS-2025-0001

FS-2025-0001-554141

Opposes rescissionA1 strongSubstance 16/24Owed an answerPosted October 5, 2026 On Regulations.gov

In short: The comment documents that the agency's proposal to rescind the Roadless Rule conflicts with its own DEIS Table 21 data on fire density, fails to demonstrate a net economic benefit given a $6.9 billion maintenance backlog, and ignores the legal precedent from the Tenth Circuit regarding the rule's validity under the Organic Act and MUSYA.

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

Recreation Tourism Public Use
- “I backpack in many areas of the national forest”
- “I want these wild places available for their children and their grandchildren”
- “The memories we create in nature are lasting and build resilience”
- “My daughter once attended a camp for diabetic children where campers hiked into the national forest”
Forest Management Wildfire
- “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”
- “open areas like Moses, Slate Mtn., and Dennison Peak to new roads in the name of wildfire management”
- “reconcile this proposal with those numbers before it proceeds”
Economic Impact Fiscal
- “the total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “The agency projects timber revenue to itself of $5.2 to $11.4 million a year, set against recreation losses of at least $6.1 million a year”
- “The Forest Service carries a $6.9 billion maintenance backlog on a road budget of roughly $73 million a year”
- “its own numbers cannot establish a net benefit”
Water Quality Quantity
- “1,034 municipal water intakes in the Pacific Southwest region sit in watersheds containing affected roadless areas”
- “Piecemeal state decisions cannot protect values of that scale”
- “I want to keep our public land clean, cared for, and free of further development”

What it names

National Forests: Sequoia National Forest
Roadless areas: Black Mtn.Dennison PeakGreenhorn CreekLion RidgeMill CreekSlate Mtn.
Law cited: 28 U.S.C. Section 1291

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 I backpack in many areas of the national forest. My first backpacking trip was in the national forest, and I now backpack with my children in places like Mill Creek, Rincon, Channell, and Greenhorn Creek in the Sequoia National Forest. I want these wild places available for their children and their grandchildren. The memories we create in nature are lasting and build resilience. We need a resilient generation now and later. That is why I oppose rescinding the 2001 Roadless Area Conservation Rule. The agency's own record on fire makes the case against this proposal better than I can. The rule's own supporting analysis 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." If the agency now proposes to open areas like Moses, Slate Mtn., and Dennison Peak to new roads in the name of wildfire management, it owes the public a full explanation of how that position squares with what its own DEIS Table 21 found about fire density on roaded versus unroaded land. I ask that the agency reconcile this proposal with those numbers before it proceeds. I am not interested in allowing more roads for logging, and the agency's own economic record does not make a compelling case that anyone should be. The rule's analysis concedes that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency projects timber revenue to itself of $5.2 to $11.4 million a year, set against recreation losses of at least $6.1 million a year and a net present value that its own Cost Benefit Analysis cannot pin above zero. When we don't have funding to maintain what is already there, how can we afford to build more roads? The Forest Service carries a $6.9 billion maintenance backlog on a road budget of roughly $73 million a year. The agency must explain how opening areas like Chico, Lion Ridge, and Black Mtn. to new roads serves the public interest when its own numbers cannot establish a net benefit. The proposal argues that state-by-state approaches can substitute for a national rule. The record shows that argument was tried before. The agency's own prior rulemaking process acknowledged "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." California alone holds 381 inventoried roadless areas covering 4,389,760 acres, and 1,034 municipal water intakes in the Pacific Southwest region sit in watersheds containing affected roadless areas. Piecemeal state decisions cannot protect values of that scale. The Ninth Circuit already found that local decision-making can incrementally erode nationally significant roadless values, and the court rejected the state-by-state substitute. How does this proposal avoid those same deficiencies? The proposal also suggests the 2001 rule exceeded the agency's authority. That question was litigated. The Tenth Circuit held, exercising jurisdiction under 28 U.S.C. Section 1291, that it would "REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The court found the rule was within the authority Congress granted under the Organic Act and MUSYA and did not create de facto wilderness. The agency must state plainly, on the record, what legal basis it believes supports a contrary position now. My daughter once attended a camp for diabetic children where campers hiked into the national forest, showing them their condition does not define who they are or what they are able to do. I want that available to others. These are the places that do that work. Nature is healing, and I want to keep our public land clean, cared for, and free of further development. I urge the agency to withdraw this proposal. Sincerely, Carrie Kears Visalia, California