Comment Analysis · Docket FS-2025-0001

FS-2025-0001-583973

Opposes rescissionA2 moderateSubstance 14/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment establishes that the agency's DEIS data (Table 21) contradicts the proposal's premise that opening roadless areas reduces fire risk, identifies a gap in the analysis regarding sediment delivery to downstream intakes, and documents specific reliance interests and economic impacts on local outfitters that the agency failed to adequately weigh in its regulatory flexibility analysis.

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

Recreation Tourism Public Use
- “wildness, quiet, and wildlife in these forests are a major reason I go there”
- “I hike and paddle across the Tonto, Coconino, and both units of the Kaibab National Forest”
- “More roads would change the very qualities that make them worth going to”
- “lost recreation benefit at a minimum of $6.1 million a year”
Forest Management Wildfire
- “When fire moves through roadless country, regeneration comes back quicker and the damage is not as severe”
- “human-caused ignitions increase in abundance with proximity to roads”
- “road access could increase the number and frequency of wildfires”
- “The agency must quantify the expected increase in human-caused ignitions that would follow from new road access”
Water Quality Quantity
- “skid roads, trails, log landings and similar disturbances within timber sale areas are the main cause of soil erosion”
- “can contribute up to 90 percent of the sediment generated by timber sale activity”
- “quantify projected sediment delivery to the more than 7,000 municipal intakes downstream of affected roadless areas”
- “preventing stream damage”
Legal Regulatory Framework
- “Under established administrative law, an agency reversing course must grapple with the reliance interests its prior policy created”
- “The agency should identify and weigh the reliance interests described in the comments it receives”
- “The small-business certification in the supporting regulatory flexibility analysis reaches its no-impact conclusion by distributing the loss across every small firm”
- “The agency should withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas”

What it names

National Forests: Kaibab National Forest

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 The wildness, quiet, and wildlife in these forests are a major reason I go there. I hike and paddle across the Tonto, Coconino, and both units of the Kaibab National Forest. I run the Salt River, the Verde, the Gila, and the Colorado. I photograph landscapes, the diversity of plants, and wildlife you can find nowhere else. These undeveloped areas define what those places are. More roads would change the very qualities that make them worth going to. I am filing this comment to oppose rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001. I also volunteer regularly with the National Forest Service. I have seen firsthand how important these areas are. When fire moves through roadless country, regeneration comes back quicker and the damage is not as severe. That observation is consistent with what peer-reviewed science shows. It is also consistent with what the agency's own data show, which makes the reasoning behind this proposal hard to follow. The agency's effects analysis quantifies human-caused ignition density at 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas, drawing on a full decade of data, and states directly that "human-caused ignitions increase in abundance with proximity to roads" (DEIS Table 21, 2014-2024). The DEIS concedes that road access could increase the number and frequency of wildfires. Yet the proposal presses forward on the premise that opening these areas reduces fire risk. The agency must quantify the expected increase in human-caused ignitions that would follow from new road access, weigh that increase against the claimed reduction in wildfire hazard, and explain the discrepancy in its final analysis. The national forest road system already exceeds 300,000 miles. The Forest Service has documented chronic underfunding of road maintenance. Explain to me how it is fiscally responsible to neglect existing road infrastructure while proposing to open what remains of our roadless forests. That question becomes sharper when the agency's own document quantifies the soil cost: the DEIS states that 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 figure appears in the document. No projection of sediment delivery to downstream water intakes follows it. The agency should quantify projected sediment delivery to the more than 7,000 municipal intakes downstream of affected roadless areas before this rule moves further. The small-business certification in the supporting regulatory flexibility analysis reaches its no-impact conclusion by distributing the loss across every small firm in the sector nationally. The agency's own Cost Benefit Analysis tells a different story: "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." The outfitters and guides who hold permits and run trips in the rivers and forests I have described are not a national average. They are specific businesses in specific places, and some of them will lose these receipts. 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. I paddle these rivers and walk these forests because they remain largely intact. That relationship is exactly the kind of interest the proposal itself invites comment on. 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. Under established administrative law, an agency reversing course must grapple with the reliance interests its prior policy created. This comment is one. The agency should identify and weigh the reliance interests described in the comments it receives, including this one, before a final rule issues. Taxpayer dollars should go toward repairing existing roads, improving drainage, and preventing stream damage. The places I photograph, paddle, and walk through have value precisely because they have been left alone. Nothing in this proposal accounts for that adequately. Sincerely, Jim Dublinski Scottsdale, AZ