Comment Analysis · Docket FS-2025-0001

FS-2025-0001-566649

Opposes rescissionA2 moderateSubstance 12/24Owed an answerPosted October 5, 2026 On Regulations.gov

In short: The comment documents that the agency's analysis fails to quantify the increase in human-caused ignitions from new roads, ignores specific reliance interests and local economic impacts on outfitters, and improperly excludes foreseeable plan amendments regarding timber harvest from the current scope of review.

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, Evidence.

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
- “Camping together in a wild space that is not overbuilt”
- “Hiking there is meaningful because it is a space of nature”
- “Roads would make the forest crowded with people”
- “lost recreation benefit at a minimum of $6.1 million a year”
Forest Management Wildfire
- “Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas”
- “human-caused ignitions increase in abundance with proximity to roads”
- “road access could increase the number and frequency of wildfires”
- “quantify the expected increase in human-caused ignitions from new road access”
Legal Regulatory Framework
- “Under established administrative law, an agency reversing course must identify and weigh the reliance interests its prior policy created”
- “The agency should withdraw the small-business certification and analyze the impact on the entities actually operating”
- “The agency is asking the public to comment on outcomes it has declared out of scope”
- “The foreseeable plan-amendment scenario... must be analyzed as part of this action”
Water Quality Quantity
- “1,034 municipal water intakes sit in watersheds containing affected roadless areas”
- “Trabuco, Ladd at 5,300 acres, and Coldwater at 8,402 acres sit within the Cleveland National Forest”
- “serves a densely developed region where wild land is already scarce”

What it names

National Forests: Cleveland National Forest

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Cleveland National Forest felt like a world away while we were there, even though it is close to where we live. My husband and I camped there early in our relationship. Camping together in a wild space that is not overbuilt helped us lay a solid foundation to our relationship. Trabuco, at 23,341 acres, is beautiful and has wild places with homes close by. Hiking there is meaningful because it is a space of nature in a county that has so much concrete and control. I oppose rescinding the 2001 Roadless Area Conservation Rule and ask the agency to respond to each of the points below. Roads would make the forest crowded with people, and more people would add light and hinder the animals from living their lives. The agency's own fire record reinforces this. "Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads." That is not a minor difference. The effects analysis concedes that road access could increase the number and frequency of wildfires, yet the proposal does not translate that concession into projected numbers. I ask that the agency quantify the expected increase in human-caused ignitions from new road access and weigh it against the claimed reduction in wildfire hazard before this rule proceeds any further. California holds 381 inventoried roadless areas totaling 4,389,760 acres, and across the Pacific Southwest region 1,034 municipal water intakes sit in watersheds containing affected roadless areas. Trabuco, Ladd at 5,300 acres, and Coldwater at 8,402 acres sit within the Cleveland National Forest, a forest that serves a densely developed region where wild land is already scarce. The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. This comment is one such interest. My husband and I built something real in that forest, and the rule that kept it intact shaped what we expected from it. Under established administrative law, an agency reversing course must identify and weigh the reliance interests its prior policy created. I ask that the agency do exactly that with the comments it receives, including this one. The economic analysis does not hold together. "The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year." The supporting regulatory flexibility analysis reaches its no-impact conclusion by spreading the $9 million annual expenditure loss across every small firm in the sector nationally rather than assessing the guides and outfitters actually holding permits in the affected areas. It then concedes some firms may lose those receipts. That is not a rigorous assessment. The agency should withdraw the small-business certification and analyze the impact on the entities actually operating in the potentially affected roadless areas, not on a national average that obscures local harm. Finally, the agency has placed its own foreseeable consequences beyond the reach of its own analysis. "The proposed rule concedes that subsequent land management plan amendments and revisions 'could increase the area where timber harvest and road construction would be allowed,' declares changes to plans beyond the scope of the proposal, and then requests public comment on them (91 FR 53830)." The agency is asking the public to comment on outcomes it has declared out of scope. A forest like the Cleveland, pressed against suburban Orange and San Diego counties, has no room for that kind of deferred accounting. The foreseeable plan-amendment scenario, including expanded timber harvest area, must be analyzed as part of this action, not handed off to a future proceeding that may offer no equivalent opportunity for public input. I urge the agency to keep the 2001 rule in place and to address each of these points with the specificity they require. Sincerely, Chandra Jenkins Deeks Anaheim, California