Comment Analysis · Docket FS-2025-0001

FS-2025-0001-577658

Opposes rescissionA1 strongSubstance 16/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment documents that the agency's rescission proposal fails to reconcile its wildfire ignition data with the proposal, lacks quantified evidence for administrative burden claims, and improperly certifies no significant impact on small entities despite its own Cost Benefit Analysis showing $6.1 million in annual lost recreation benefits.

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

Water Quality Quantity
- “concerned about water conservation as temperatures and drought continue to increase”
- “1,466 municipal water intakes sit in watersheds containing affected roadless areas”
- “roads and their facilities can produce up to 90 percent of the sediment from a timber sale”
- “less reliable water for the people and communities downstream”
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”
- “Opening roadless areas to road construction does not reduce ignition risk”
- “far higher fire density on roaded land than inside the affected roadless areas”
Recreation Tourism Public Use
- “hear running water and birdsong and to clear my head”
- “future generations to have access to the outdoors and to the health benefits of spending time outside”
- “lost recreation benefit at a minimum of $6.1 million a year”
- “names outfitters, guides, and tour operators as affected parties”
Governance Policy Process
- “The Forest Service held more than 600 public meetings and received 1.6 million comments before writing this rule”
- “It has held none before undoing it”
- “The rescission process has been neither [extensive and public]”
- “agency changing course is obligated to assess the reliance its prior policy created”

What it names

National Forests: Angeles National Forest
Law cited: 36 C.F.R. Section 294.12

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Angeles National Forest is where I go to hear running water and birdsong and to clear my head. I also lived in Utah for a time and came to love the Utah backcountry. Both of those places are shaped by the 2001 Roadless Area Conservation Rule. I oppose its rescission under Docket FS-2025-0001. Utah holds 222 inventoried roadless areas totaling 4,013,529 acres. As a westerner, I am concerned about water conservation as temperatures and drought continue to increase. Across the Intermountain region, which includes Utah, 1,466 municipal water intakes sit in watersheds containing affected roadless areas. Rescinding the rule places those watersheds under real and quantifiable pressure. The agency's own analysis documents that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Fewer unroaded areas means more sediment, more impaired streams, and less reliable water for the people and communities downstream. I ask that the agency explain, with specificity, how removing protections from roadless watersheds across the Intermountain region is consistent with any credible commitment to water quality and drought resilience. The proposal justifies rescission partly on wildfire and fuels management grounds. The agency's own record 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." The Angeles and the Utah backcountry I care about are both fire-prone landscapes. Opening roadless areas to road construction does not reduce ignition risk; the agency's own data say the opposite. The agency must explain why the proposal departs from these prior findings and reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. The proposal also cites permitting and administrative burden as justification. But the rule as written already accommodates the agency's stated concerns. The agency's own text notes that the rule "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." If the existing exceptions for health, safety, and reserved rights are insufficient, the agency has not shown where they fall short or put numbers to the gap. It should identify, specifically and by category, which burdens the current exceptions do not already address, and quantify those burdens. I want future generations to have access to the outdoors and to the health benefits of spending time outside. The Forest Service held more than 600 public meetings and received 1.6 million comments before writing this rule. It has held none before undoing it. The Utah backcountry and the forests near Los Angeles that I value were protected by a process that was extensive and public. The rescission process has been neither. The agency's own analysis concedes that its Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year, and names outfitters, guides, and tour operators as affected parties, yet "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 is reached by spreading losses across every small firm in the sector nationally rather than assessing the businesses actually holding permits in affected areas. The agency should withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas. Finally, 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. I have organized my relationship to these landscapes around the assumption that they would remain protected. An agency changing course is obligated to assess the reliance its prior policy created, not simply invite comment and then ignore what it receives. The agency must identify and genuinely weigh the reliance interests described in the comments it collects, including this one. Sincerely, Zak Breckenridge Long Beach, CA