Comment Analysis · Docket FS-2025-0001

FS-2025-0001-571022

Opposes rescissionA2 moderateSubstance 11/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment documents deficiencies in the agency's regulatory flexibility analysis and failure to weigh solicited reliance interests, while citing specific DEIS data on fire ignition densities and road maintenance backlogs to argue that rescinding the Roadless Rule would increase wildfire risk and economic burdens without adequate funding.

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

Wildlife Habitat
- “Jaguars have been documented crossing from Mexico through the Santa Ritas”
- “Elegant trogon, Mexican spotted owl, Gould's turkey, Arizona treefrog, and ocelot depend on the same corridors”
- “roadless corridors between them are the only pathways that make movement across that landscape viable”
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”
- “road access could increase the number and frequency of wildfires”
- “agency must quantify the expected increase in human-caused ignitions that new road access would bring”
Economic Impact Fiscal
- “My tax money should not build new roads into country that has none”
- “deferred maintenance backlog of $6.9 billion for roads and bridges”
- “lost recreation benefit at a minimum of $6.1 million a year”
Legal Regulatory Framework
- “The agency also invited comment on reliance and then did nothing with it”
- “Under the legal standards that govern an agency changing course, those interests must be identified and weighed”
- “I ask that the agency withdraw the certification and assess the impact on the small entities actually operating”

What it names

National Forests: Coronado National Forest
Works cited: Furniss et al. 1991

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 The sky islands of the Coronado National Forest are already being squeezed from every direction. I hike in the Coronado and in the national forests of Utah, Northern Arizona, and Oregon, and what draws me to those places is exactly what this proposal would put at risk: country that has no roads in it yet. I oppose the rescission of the 2001 Roadless Area Conservation Rule. The Coronado holds 23 inventoried roadless areas totaling 482,687 acres. The Santa Ritas, Chiricahuas, Galiuros, and Rincons are sky islands, each one a cool forest standing in a sea of hot desert, and the roadless corridors between them are the only pathways that make movement across that landscape viable. Jaguars have been documented crossing from Mexico through the Santa Ritas into the Rincon Mountains and beyond. That is the northernmost extent of jaguar range. Elegant trogon, Mexican spotted owl, Gould's turkey, Arizona treefrog, and ocelot depend on the same corridors. Roadless areas are rare, and only getting more rare. We should protect rare things that have value. A logged stand grows back; the agency's own analysis acknowledges that roads do not. The agency's cost accounting here does not add up. The proposed rule certifies no significant impact on small entities, yet the record beneath that certification tells a different story: "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 regulatory flexibility analysis reaches its no-impact conclusion by spreading losses across every small firm in the sector nationally, not the outfitters and guides who actually hold permits in the affected areas, and then concedes some of those firms may lose those receipts. That is not a meaningful assessment. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. The agency also invited comment on reliance and then did nothing with it. 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. My use of these forests, and my expectation that unroaded country will remain unroaded, is precisely the kind of reliance interest that solicitation called for. Under the legal standards that govern an agency changing course, those interests must be identified and weighed, not invited and ignored. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one. The agency's own fire data argues against opening these areas. "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." The effects analysis concedes that road access could increase the number and frequency of wildfires. If the stated justification for the proposal includes reducing wildfire hazard, the agency must quantify the expected increase in human-caused ignitions that new road access would bring and weigh it honestly against that claimed benefit. My tax money should not build new roads into country that has none, especially when the agency cannot maintain the roads it already has. Please do not use my tax money to build new roads. There are plenty as is, and they create long-term damage. The record confirms the problem: "Road appropriations fell from $234 million in 2004 to $73 million in 2024, against a deferred maintenance backlog of $6.9 billion for roads and bridges, with supplemental funding expiring." Utah alone holds 222 inventoried roadless areas totaling 4,013,529 acres, and across the Intermountain region 1,466 municipal water intakes sit in watersheds containing affected roadless areas. The DEIS states that road mileage, deferred maintenance, and management costs are likely to increase under the proposal. The agency must name the funding source for any new road construction and maintenance and state plainly what the projected change to the backlog would be. Sincerely, Levi Tenen Norfolk, VA (but native Arizonan)