Comment Analysis · Docket FS-2025-0001

FS-2025-0001-564305

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

In short: The comment establishes that the agency's draft environmental impact statement fails to reconcile the proposed rescission with its own data in DEIS Table 21 regarding fire density, contradicts the Tenth Circuit's legal holding on statutory authority, and relies on a flawed regulatory flexibility analysis that obscures local economic impacts on small entities in the Santa Rita Mountains.

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

Wildlife Habitat
- “jaguars documented crossing from Mexico through the Santa Ritas”
- “Elegant trogon, Mexican spotted owl, Gould's turkey, Arizona treefrog, and ocelot depend on the same connected landscape”
- “severs biological pathways that took geological time to form”
- “connective tissue between some of the most biologically extraordinary landscapes”
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 the rescission with the ignition data in its own DEIS Table 21”
- “far higher fire density on roaded land than inside the affected roadless areas”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “recreation losses of at least $6.1 million a year”
- “Forest Service is already carrying a $6.9 billion maintenance backlog”
- “agency cannot establish a net benefit from doing so”
Legal Regulatory Framework
- “Tenth Circuit addressed that argument and was unambiguous”
- “found the rule within the authority granted by the Organic Act and MUSYA”
- “regulatory flexibility certification that accompanies this proposal cannot withstand scrutiny”
- “agency must withdraw that certification and assess the impact on the small entities”

What it names

National Forests: Coronado National Forest
Roadless areas: Santa Rita
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 gapEvidenceRequestLegal

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Santa Rita Mountains of southern Arizona are where I learned to camp and backpack. I was born and raised in Arizona, and those mountains, along with the deserts surrounding them, shaped everything I understand about wild country. The sky islands of the Coronado National Forest, ranging across the Santa Ritas, Chiricahuas, Galiuros, and Rincons, are the connective tissue between some of the most biologically extraordinary landscapes on this continent. Each range is an island of cool forest in a sea of hot desert. The Coronado holds 23 inventoried roadless areas totaling 482,687 acres, and I am writing to oppose rescinding the protections that have kept them intact. The wildfire rationale offered for this rescission is the place I want to start, because the agency's own record contradicts it. The 2001 rule's environmental analysis found that "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." That finding was made on the basis of the agency's own data, and the draft environmental impact statement supporting the current proposal does nothing to repudiate it. The Santa Ritas are precisely the kind of high-value, fire-prone landscape that finding was meant to protect. I ask the agency to reconcile the rescission with the ignition data in its own DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas, and explain why the proposal departs from findings its own staff put into the record. The economic case for rescission is equally unsupportable on its own numbers. The agency's record states 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." Against revenues that negligible, the agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year, with a net present value ranging from -$92 million to +$199 million. The Forest Service is already carrying a $6.9 billion maintenance backlog on its existing road system. What justification exists for expanding that system when the agency cannot establish a net benefit from doing so? I ask the agency to answer that question directly and in writing before this rule moves forward. The legal authority question deserves the same directness. The proposal suggests the 2001 rule exceeded statutory authority. The Tenth Circuit addressed that argument and was unambiguous: "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 granted by the Organic Act and MUSYA and did not find it created de facto wilderness. I ask the agency to explain on the record what legal basis it believes supports a contrary reading, given that holding. The jaguars documented crossing from Mexico through the Santa Ritas into the Rincon Mountains represent the northernmost extent of jaguar range in North America. The roadless corridors between the sky islands are, by the agency's own verified record, the only pathways that make that range viable. Elegant trogon, Mexican spotted owl, Gould's turkey, Arizona treefrog, and ocelot depend on the same connected landscape. Opening these corridors to roads does not merely affect scenery. It severs biological pathways that took geological time to form. Arizona holds 78 inventoried roadless areas totaling 1,174,256 acres, and across the Southwestern region, 739 municipal water intakes sit in watersheds containing affected roadless areas. The cumulative stakes of this rescission extend well past the individual ranges I know best. Finally, the regulatory flexibility certification that accompanies this proposal cannot withstand scrutiny. The DEIS names outfitters, guides, and tour operators as entities affected by the action, and the agency's own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. The agency reached its no-significant-impact conclusion by distributing that loss across every small firm nationally rather than examining the businesses holding permits in the areas actually at risk. The agency must withdraw that certification and assess the impact on the small entities operating in the potentially affected roadless areas, not a national average that obscures the local reality. Sincerely, Brandi Martinez Chandler, AZ