Comment Analysis · Docket FS-2025-0001

FS-2025-0001-579578

Opposes rescissionA1 strongSubstance 15/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment documents that the agency's proposal to rescind the Roadless Area Conservation Rule is internally inconsistent with its own DEIS data on wildfire ignition rates and economic costs, fails to analyze foreseeable plan amendments, and ignores the existing regulatory exceptions that already address public health and safety.

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

Recreation Tourism Public Use
- “Backpacking into the Sierra Nevada is for me as it was for John Muir”
- “immersion in wilderness to refresh the human spirit”
- “enhance our recreational opportunities”
- “recreation losses of at least $6.1 million a year”
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”
- “reconcile this proposal with the ignition data in its own DEIS Table 21”
- “community wildfire protection”
Water Quality Quantity
- “water that originates in the Tuolumne River roadless area... reaches communities downstream”
- “without the watershed degradation that follows road construction”
- “roads and their facilities can produce up to 90 percent of the sediment from a timber sale”
- “Fewer than 12 percent of watersheds fed by roadless areas have impaired streams today”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “road maintenance backlog of $6.9 billion against a road budget of roughly $73 million a year”
- “timber revenue of $5.2 to $11.4 million a year against recreation losses”
- “responsible use of public funds”

What it names

National Forests: Los Padres National Forest Sierra National Forest Stanislaus National Forest
Roadless areas: Bear CanyonDevil GulchSan JoseTuolumne River
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 analysisAnalytical gapEvidenceRequestAlternativeLegal

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Backpacking into the Sierra Nevada is for me as it was for John Muir. There is no substitute for immersion in wilderness to refresh the human spirit, and when I travel to places like the Tuolumne River roadless area in the Stanislaus National Forest or Devil Gulch in the Sierra National Forest and capture that beauty on my phone, the people back home are delighted beyond measure by the glimpse into the natural world. That experience is what I am defending here. I oppose rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001, and I ask that this letter be entered into the record in full. The agency's own language on wildfire risk undercuts the case for rescission before that case can be made. The 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." If the agency now proposes to open the Sierra Nevada roadless areas and others like Bear Canyon in the Los Padres National Forest to new road construction on fuels-management grounds, it must explain how that action is consistent with those words. I ask that the agency reconcile this proposal with the ignition data in its own DEIS Table 21 and explain why it departs from its prior findings on fire occurrence and fuel treatment inside roadless areas. The economic rationale offered for rescission is, by the agency's own numbers, unconvincing. The record holds: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Americans like me expect the Forest Service to spend its budget, which originates with taxes we pay, in a transparent and responsible manner. We want those funds used to better maintain existing infrastructure and to enhance our recreational opportunities, not to build new roads into areas the rule now protects. That expectation only sharpens when the agency's own Cost Benefit Analysis cannot establish a net benefit and when the agency is already carrying a road maintenance backlog of $6.9 billion against a road budget of roughly $73 million a year. I ask that the agency reconcile this proposal with its own economic analysis, which projects timber revenue of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year and a net present value ranging from -$92 million to +$199 million, and explain how expanding a road system carrying that backlog is a responsible use of public funds. The rule the agency proposes to rescind already contains the flexibility it now cites as justification for rescission. The record acknowledges 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 those exceptions already address public health emergencies, existing mineral leases, and community wildfire protection, then full rescission is not the narrowly tailored response the agency owes the public. The agency must identify, with specificity, which burdens the existing exceptions do not already resolve, and it must quantify them. The water that originates in the Tuolumne River roadless area and in the other Sierra Nevada inventoried roadless areas reaches communities downstream. Americans like me want those water supplies to remain healthy, without the watershed degradation that follows road construction and heavy equipment operations. The agency's own analysis found that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Fewer than 12 percent of watersheds fed by roadless areas have impaired streams today. Opening these areas to roads risks that record. Finally, the process the agency used to justify rescission is itself defective. 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 cannot simultaneously declare foreseeable consequences out of scope and invite comment on them. There were more than 600 public meetings to make the rule, but none to undo it. Americans like me want our kids to inherit the same wild places we did. The agency must analyze the foreseeable plan-amendment scenario, including expanded timber harvest area, as a full part of this action before any final decision is made. Sincerely, Kimberly S San Jose, CA