Comment Analysis · Docket FS-2025-0001

FS-2025-0001-562561

Opposes rescissionA1 strongSubstance 14/24Owed an answerPosted October 5, 2026 On Regulations.gov

In short: The comment establishes that the agency's proposal to rescind the 2001 Roadless Area Conservation Rule is internally inconsistent with its own DEIS findings on wildfire ignition rates and economic cost-benefit analyses, and requests that the agency explain how the proposal reconciles these deficiencies and avoids previously identified legal errors.

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, 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
- “Dispersed camping in the national forests is what I go to these areas for”
- “places I go to escape”
- “recreation losses of at least $6.1 million a year”
Wildlife Habitat
- “wildlife that makes them worth photographing depends on the quiet that roads would end”
- “They scatter wildlife and disrupt the natural ecosystems”
- “natural ecosystems that give these landscapes their value”
Forest Management Wildfire
- “Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “reconcile that departure with the fire-density data in DEIS Table 21”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “net present value range spanning -$92 million to +$199 million”
- “Forest Service is already carrying a $6.9 billion road maintenance backlog”

What it names

National Forests: Sequoia National Forest
Roadless areas: Black Mtn.Greenhorn 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 Dispersed camping in the national forests is what I go to these areas for, and I want to be plain about what I stand to lose. The roadless areas of Sequoia National Forest, including Black Mtn. at 15,102 acres, Lion Ridge at 5,265 acres, Greenhorn Creek at 28,226 acres, Slate Mtn. at 12,299 acres, Chico at 39,836 acres, and Mill Creek at 27,643 acres, are places I go to escape. They are also places I photograph, and the wildlife that makes them worth photographing depends on the quiet that roads would end. Roads bring traffic, trash, and people in volumes that these areas were never built to absorb. They scatter wildlife and disrupt the natural ecosystems that give these landscapes their value. I oppose the rescission of the 2001 Roadless Area Conservation Rule and ask that this comment be entered into the record for Docket FS-2025-0001. The agency frames this proposal partly as a wildfire and fuels management measure. Its own analysis does not support that framing. The DEIS 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 build roads into inventoried roadless areas as a fire-management tool, it must explain how that squares with its own finding that roaded lands carry a dramatically higher ignition rate, and it must reconcile that departure with the fire-density data in DEIS Table 21. The economic case for rescission is just as weak. The agency's record already acknowledges 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's own Cost Benefit Analysis projects timber revenues to the Forest Service of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year, with a net present value range spanning -$92 million to +$199 million. It cannot establish that this action produces a net benefit. Meanwhile, the Forest Service is already carrying a $6.9 billion road maintenance backlog. Rescinding the rule to add roads to a system the agency cannot currently maintain, in pursuit of commodity outputs that represent a fraction of a percent of national production, is what I mean when I say this opens opportunities for unsustainable corporate greed to take over our public lands. The agency must explain on the record how a proposal whose own analysis fails to demonstrate a net benefit justifies expanding that backlog further. The agency argues that state-by-state approaches can replace a single national rule. That argument has already been tested. The agency's 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 rejected the state-petition approach that followed. California alone holds 381 inventoried roadless areas totaling 4,389,760 acres, and the Pacific Southwest region, which includes California, has 1,034 municipal water intakes sitting in watersheds containing affected roadless areas. Piecemeal state processes have already proven inadequate to protect values at that scale. The agency must explain how this proposal avoids the legal deficiencies the Ninth Circuit identified when the agency last walked this path. Finally, the agency questions whether the 2001 rule exceeded its statutory authority. A federal appellate court already answered that question. The Tenth Circuit held: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we 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." That court found the rule within the authority Congress granted under the Organic Act and MUSYA and held that it did not create de facto wilderness. The agency owes a direct explanation of what legal basis it believes supports a contrary position today. The roadless rule already accounts for management of these forests. Rescinding it does not improve management. It removes a protection that courts have upheld, that the agency's own data shows reduces fire ignition, and that stands between the remote places I value and the damage that roads reliably bring. Sincerely, J Fry Visalia, CA