Comment Analysis · Docket FS-2025-0001

FS-2025-0001-574139

Opposes rescissionA2 moderateSubstance 16/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment documents that the agency's record fails to honestly address the impacts of rescinding the Roadless Rule on local recreation access, water quality (specifically sediment loading affecting 1,034 intakes), wildfire risk (citing DEIS Table 21 data), and small entity reliance interests, while also alleging that the NEPA alternatives analysis was improperly constrained by deregulatory executive orders.

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, Alternative.

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
- “escape from the concrete city”
- “only outdoor recreation space they have the ability to visit”
- “destroying open spaces for all”
- “lost recreation benefit at a minimum of $6.1 million a year”
Water Quality Quantity
- “drinking water is already at risk”
- “1,034 municipal water intakes sitting in watersheds”
- “roads and their facilities can produce up to 90 percent of the sediment”
- “maintaining water supply for the populations”
Governance Policy Process
- “analysis built to reach a predetermined conclusion”
- “regulatory flexibility analysis does not survive scrutiny”
- “ignored them... solicits 'any reliance interests'”
- “range of alternatives the agency considered was never real”
Forest Management Wildfire
- “Human-caused ignition density is 22.4 fires per million acres”
- “human-caused ignitions increase in abundance with proximity to roads”
- “road access could increase the number and frequency of wildfires”
- “communities already living with wildfire risk”

What it names

National Forests: Cleveland National Forest
Roadless areas: Ladd

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The roadless areas near where I live are an escape from the concrete city around us. For many people in this part of Southern California, including those who visit the Ladd roadless area in Cleveland National Forest, these 5,300 acres represent the only outdoor recreation space they have the ability to visit. I oppose rescission of the 2001 Roadless Area Conservation Rule because the agency's own record does not support it, and because the people who depend on these lands deserve better than an analysis built to reach a predetermined conclusion. Public lands need to be managed for public use, not for privatizing and stripping of all natural resources. That approach enriches a few while destroying open spaces for all. California holds 381 inventoried roadless areas totaling 4,389,760 acres, and the question before the agency is whether all of that, including the places closest to densely populated communities with no other realistic access to wildland, should be opened to the roads and extraction that the 2001 rule was written to prevent. Nothing in the record answers that question honestly. Our drinking water is already at risk, and rescission would further strain the resources and agencies involved in delivering drinking water to Southern California residents. The Pacific Southwest region, which includes California, has 1,034 municipal water intakes sitting in watersheds that contain affected roadless areas. The agency's own analysis acknowledges that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Losing the rule's protection over these watersheds is not an abstraction for communities here. I ask the agency to explain on the record how that sediment loading is consistent with maintaining water supply for the populations those 1,034 intakes serve. The regulatory flexibility analysis does not survive scrutiny. 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. That certification was reached by spreading the expenditure loss across every small firm in the sector nationally rather than assessing the operators actually holding permits in the affected areas. The agency must withdraw that certification and conduct an analysis focused on the small entities actually operating in the potentially affected roadless areas, not on a national average that obscures the real harm. The agency also invited reliance interests and then ignored them. 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. Communities, recreationists, and small businesses have organized their expectations around the protections the 2001 rule created for more than two decades. This comment is exactly the kind of reliance interest the agency asked to hear about. The agency should identify and weigh those interests, including this one, before any final action is taken. The fire data the agency collected cuts against its own proposal. 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. For communities already living with wildfire risk in Southern California, that is not a minor footnote. The agency must quantify the expected increase in human-caused ignitions from new road access and set that figure honestly against whatever wildfire hazard reduction it claims to offer. Finally, the range of alternatives the agency considered was never real. Alternatives with more protection were dismissed as not responsive to the deregulatory executive orders, and the keep-boundaries option was cut because it "would continue to restrict local decision-making discretion" and because analysing roadless values is "an administrative and legal burden for the agency." A purpose and need statement written entirely around deregulation forecloses the comparison NEPA was designed to require. The agency should restate the purpose and need in terms of actual forest conditions and analyse at least one fully protective alternative before this proceeding goes any further. Sincerely, SR CA