Comment Analysis · Docket FS-2025-0001

FS-2025-0001-583761

Opposes rescissionA1 strongSubstance 14/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment documents that the agency's DEIS fails to project sediment delivery to downstream municipal intakes despite acknowledging that timber sale disturbances cause up to 90% of sediment, fails to identify specific enforceable forest plan provisions equivalent to 36 CFR 294.12 and 294.13 for water protection, and ignores a Tenth Circuit holding that the 2001 Roadless Rule is within statutory authority.

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, 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
- “quantify projected sediment delivery to the more than 7,000 municipal intakes”
- “Approximately 24 million people use water originating within the potentially affected roadless areas”
- “Clean drinking water is more limited still”
- “identify, forest by forest, which plan provisions are equivalent to 36 CFR 294.12 and 294.13 for municipal watersheds”
Wildlife Habitat
- “landlocked coastal steelhead”
- “destroying the natural habitat those fish depend on”
- “Removing riparian vegetation raises stream temperatures beyond what suits cold-water species”
- “warmer temperatures reduce egg survival, rearing densities and growth of coho salmon”
Legal Regulatory Framework
- “A federal appellate court reviewed that question directly and held otherwise”
- “The Tenth Circuit found the 2001 rule was within the authority Congress granted”
- “explain the basis for any position contrary to that holding”
- “address that court's reasoning directly”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “total oil and gas production from all National Forest System lands is currently about 0.4 percent”
- “$73 million annual road budget and a $6.9 billion maintenance backlog”
- “spending more to open country that has no roads is a poor decision”

What it names

National Forests: Angeles National Forest Inyo National Forest
Roadless areas: West Fork
Law cited: 28 U.S.C. Section 1291 36 CFR 294.12

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The East and West Fork of the San Gabriel Rivers are not wilderness by any formal designation, but they hold landlocked coastal steelhead, and they are close enough to Los Angeles that people who love them share the water with people who abuse it. I have watched gold miners dig out whole sides of the stream, sending sediment downriver and destroying the natural habitat those fish depend on. I have seen illegal camping all up and down the river creating public health hazards with elevated E. coli. Rescinding the 2001 Roadless Area Conservation Rule for the Angeles National Forest will not reduce that pressure. It will increase it, and it will do so while the agency's own science documents exactly what new roads cost a river. The agency's document states: "The DEIS: skid roads, trails, log landings and similar disturbances within timber sale areas are the main cause of soil erosion and 'can contribute up to 90 percent of the sediment generated by timber sale activity.'" That number appears in the record and then vanishes. No projection follows it. Removing riparian vegetation raises stream temperatures beyond what suits cold-water species, and warmer temperatures reduce egg survival, rearing densities and growth of coho salmon. The affected area includes Essential Fish Habitat and critical habitats managed by NMFS. If the agency knows roads and their facilities can produce up to 90 percent of the sediment from a timber sale, it must quantify projected sediment delivery to the more than 7,000 municipal intakes downstream of these areas. I am asking for that calculation. The drinking water question is not abstract. The agency's own record states: "Approximately 24 million people use water originating within the potentially affected roadless areas, through more than 7,000 municipal intakes, and less than 12 percent of these watersheds are currently impaired." Water is limited already. Clean drinking water is more limited still. Many of these watersheds feed into aquifers and aqueducts that sustain cities and communities, and the current impairment rate is low precisely because the roadless rule has been holding. The DEIS asserts that forest plans address municipal water sources without identifying a single enforceable provision. I ask that the agency identify, forest by forest, which plan provisions are equivalent to 36 CFR 294.12 and 294.13 for municipal watersheds, and that it do so specifically, not by category. The proposal also argues that the 2001 rule exceeded the agency's statutory authority. A federal appellate court reviewed that question directly and held otherwise: "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 Tenth Circuit found the 2001 rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. I ask that the agency explain the basis for any position contrary to that holding, and that it address that court's reasoning directly. On the economics, the proposal rests in part on timber and energy arguments. The agency's own record states that "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." With a $73 million annual road budget and a $6.9 billion maintenance backlog already in place, spending more to open country that has no roads is a poor decision that goes against any serious principle of avoiding government waste. I also value the Inyo National Forest for its remoteness and high altitude, qualities that exist because development has not reached them. The agency must reconcile this proposal with its own Cost Benefit Analysis, which cannot establish a net benefit, and explain how expanding a road system already carrying a $6.9 billion maintenance backlog serves the public interest. I oppose rescission of the 2001 Roadless Area Conservation Rule. The agency has quantified the harm and declined to follow it to its conclusions. That is not a reasoned decision. The record requires answers, and the public deserves them. Sincerely, Dorothy Dai Los Angeles, CA