Comment Analysis · Docket FS-2025-0001

FS-2025-0001-579473

Opposes rescissionA1 strongSubstance 13/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment documents that the agency's DEIS and Cost Benefit Analysis contain internal contradictions regarding fire density, economic net benefits, and ecological impacts (specifically bird abundance and sedimentation) that the commenter requests be reconciled, and cites specific legal precedents and regulatory citations to challenge the proposal's legal and analytical basis.

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

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”
- “far higher fire density on roaded land than inside the affected roadless areas”
Wildlife Habitat
- “Mexican spotted owl, Gould's turkey, Arizona tree frog, and ocelot also depend on these intact areas”
- “bird richness declines with road presence in forested habitat”
- “road-noise experiments in a roadless area cut bird abundance by over a quarter”
- “Fragmentation does not just inconvenience visitors. It unravels the ecosystems”
Water Quality Quantity
- “preserving what clean water sources we have left is imperative right now”
- “robust ecosystems that protect water sources matter more, not less”
- “roads and their facilities can produce up to 90% of the sediment from a timber sale”
- “address what rescission means for watershed integrity”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5% of total United States production”
- “recreation losses of at least $6.1 million a year and a net present value ranging from -$92 million to +$199 million”
- “agency already carries a $6.9 billion maintenance backlog on its existing road system”
- “Building new roads into new and difficult terrain will only deepen that hole”

What it names

National Forests: Coronado National Forest
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 gapEvidenceRequest

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I have spent time across every National Forest in Arizona, and each one has given me unforgettable experiences. I grew up in the forests, lakes, and rivers of Minnesota, and I credit that landscape as my conservation spark. These places sustain my wellbeing. I am a conservation scientist, with a degree in Conservation Biology and Ecology with a minor in Sustainability. The threats that rescinding the Roadless Area Conservation Rule would create are not up for debate in the scientific community. I oppose this proposal without reservation. The agency's own record on fire should end the wildfire argument for rescission before it begins. The DEIS 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." I ask that the agency explain how the proposal departs from that finding, and that it reconcile the rescission with DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic case is no stronger. The agency's own record concedes that "the total timber volume affected by this rule is less than 0.5% of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4% of the current national production." Against projected timber revenue to the Forest Service of $5.2 to $11.4 million a year, the agency's own Cost Benefit Analysis projects recreation losses of at least $6.1 million a year and a net present value ranging from -$92 million to +$199 million. That range cannot establish a net benefit. Meanwhile, the agency already carries a $6.9 billion maintenance backlog on its existing road system against a road budget of roughly $73 million a year. Building new roads into new and difficult terrain will only deepen that hole. There is nothing to gain and everything to lose here. I ask that the agency reconcile the proposal with those numbers and explain how it justifies expanding a road network already collapsing under deferred maintenance. The Coronado National Forest holds 23 inventoried roadless areas totaling 482,687 acres spanning across southern Arizona. These sky islands and the roadless corridors between them are the connective tissue that makes the whole system function. Mexican spotted owl, Gould’s turkey, Arizona tree frog, and ocelot also depend on these intact areas. The DEIS itself cites findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31% of species avoiding the noise entirely. Fragmentation does not just inconvenience visitors. It unravels the ecosystems that make the wildlife present in the first place. I ask that the agency address specifically how it weighs those documented impacts to bird communities and sky island connectivity against the marginal resource extraction values its own analysis could not confidently net positive. On water: preserving what clean water sources we have left is imperative right now. As climate change causes unpredictable shifts in our global system and water demands heighten by data centers and other infrastructure, robust ecosystems that protect water sources matter more, not less. The agency's own analysis says roads and their facilities can produce up to 90% of the sediment from a timber sale. The agency must address what rescission means for watershed integrity, and it must do so with specificity, not generality. The proposal argues that state-by-state approaches can substitute for a national rule. The agency's own record answers that: "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The 9th Circuit has already reviewed what happens when the agency replaces the national rule with state petitions, and it went poorly. The agency must explain how this proposal avoids those same deficiencies. On authority, the 10th Circuit has already ruled: "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." The agency must address that holding and state plainly the basis for any contrary legal position it now intends to advance. We are at a moment when we desperately need to foster connection and stewardship with this quickly changing world. Rescinding the Roadless Rule moves in exactly the wrong direction. I urge the agency to withdraw this proposal. Sincerely, Emma Rubin Glendale, AZ