Comment Analysis · Docket FS-2025-0001

FS-2025-0001-580150

Opposes rescissionA2 moderateSubstance 15/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment documents that the agency's analysis fails to quantify the increase in human-caused ignitions from new road access, incorrectly certifies no significant impact on small entities despite specific local losses, ignores solicited reliance interests, and fails to apply cited biodiversity fragmentation data to the affected acreage.

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

Forest Management Wildfire
- “increased fire risk”
- “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 wildfire frequency”
Environmental Protection Biodiversity
- “biodiversity consequences of the proposal are documented”
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
- “A few spaces should stay totally wild and free”
Governance Policy Process
- “The agency must identify and weigh the reliance interests described in the comments”
- “The claim that small businesses will not be significantly affected is not credible”
- “The agency should withdraw the certification and assess the impact on the small entities actually operating”
Water Quality Quantity
- “1,034 municipal water intakes sitting in watersheds containing affected roadless areas”
- “scale of downstream consequence”

What it names

National Forests: Los Padres National Forest
Roadless areas: Garcia Mountain

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 natural beauty I have witnessed at Garcia Mountain is something I want my kids to be able to experience. Rescinding the Roadless Area Conservation Rule directly threatens that, through increased fire risk and increased mineral extraction and mining. We have plenty of spaces for industry. A few spaces should stay totally wild and free for every person to enjoy. The fire data in the agency's own analysis makes this concrete. "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." Garcia Mountain sits within Los Padres National Forest, one of the forests in California's 4,389,760 acres of inventoried roadless land, and the contrast in those ignition figures describes exactly what I am worried about for it. The effects analysis itself concedes that road access could increase wildfire frequency, yet the proposal does not quantify what that increase would look like. I ask that the agency quantify the expected increase in human-caused ignitions from new road access and weigh it against the claimed reduction in wildfire hazard before this rescission proceeds. The claim that small businesses will not be significantly affected is not credible on the face of the agency's own documents. "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 examining the outfitters and guides who actually hold permits in the affected areas. The analysis concedes that some firms may lose those receipts entirely, which is not a no-impact result for those firms. The agency should 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 proposal itself acknowledges that people have built expectations around the current rule and invites comment on those expectations, yet never accounts for them in the analysis. "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 interest in being able to bring my kids to a place like Garcia Mountain, knowing its 7,850 acres remain unroaded, is exactly the kind of reliance interest the solicitation describes. Under established administrative law, an agency that changes course must grapple with the reliance interests its prior policy created, not simply invite them and ignore them. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. Finally, the biodiversity consequences of the proposal are documented and then left unapplied. "The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent." That range appears in the record. No projection of what it means across the 40.1 million acres of potentially affected environment follows. The 1,034 municipal water intakes sitting in watersheds containing affected roadless areas across the Pacific Southwest region alone suggest the scale of downstream consequence. The agency should apply the cited fragmentation range to the 40.1 million acres of potentially affected environment and explain what the results mean for the proposal. Sincerely, Emmet Arries Atascadero, California