Comment Analysis · Docket FS-2025-0001

FS-2025-0001-589564

Opposes rescissionA2 moderateSubstance 11/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment documents specific deficiencies in the agency's analysis regarding wildfire risk, water quality, and economic benefits by citing the DEIS and economic analyses, and requests the withdrawal of the proposal to rescind the Roadless Area Conservation Rule.

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.

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
- “The quiet I go looking for... is already hard to find”
- “I have hiked and camped in these places since childhood, going there for quiet”
- “residents of the Los Angeles metropolitan area who need relief from constant noise, light, and traffic”
- “recreation losses of at least $6.1 million a year”
Wildlife Habitat
- “to see and hear the wildlife”
- “watched a bald eagle sweep out of the sky”
- “essential for wildlife like the mountain lion that need uninterrupted space to roam and hunt”
- “bird richness declines with road presence in forested habitat”
Water Quality Quantity
- “contamination of the water table”
- “24 million Americans' drinking water coming from roadless areas”
- “roads and their facilities can produce up to 90 percent of the sediment from a timber sale”
- “739 municipal water intakes sit in watersheds containing affected roadless areas”
Forest Management Wildfire
- “The wildfire justification offered for this rescission is contradicted by the agency's own findings”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “ignition data in its own DEIS, which shows far higher fire density on roaded land”

What it names

National Forests: Angeles National Forest Jefferson National Forest
Roadless areas: Brush 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 quiet I go looking for in Jefferson National Forest, in the Sawtooth Mountains in Idaho, and in national forests and BLM land across Arizona, Utah, Washington, and Oregon is already hard to find. It is harder every decade. I have hiked and camped in these places since childhood, going there for quiet, to escape light pollution, and to see and hear the wildlife. I have sat by a river in the Sawtooth Mountains and watched a bald eagle sweep out of the sky and take a fish from the water. That is not a small thing. Rescinding the Roadless Area Conservation Rule puts that kind of experience, and the places that make it possible, at permanent risk. Brush Mountain in Jefferson National Forest is supposed to be protected from the ills that have already devastated much of Appalachia: mountaintop removal, deforestation, displacement of wildlife, contamination of the water table. It is supposed to be a place for nature to recover and thrive. Angeles National Forest is not only essential for wildlife like the mountain lion that need uninterrupted space to roam and hunt, but for the residents of the Los Angeles metropolitan area who need relief from constant noise, light, and traffic. A road into either place means more noise, more pollution, a total corruption of the environment for people, animals, plants, and water. The agency owes the public a direct explanation of how opening these 6,002 and 7,245 acres, respectively, to road-building serves a purpose commensurate with what would be destroyed. The agency's own record addresses bird abundance in roadless areas, and the findings are unambiguous. The DEIS cites the 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 percent of species avoiding the noise entirely. The bald eagles, the countless other birds I go to these places to find: the science on what roads do to them is already in the record. The agency must explain why it is proceeding anyway. The wildfire justification offered for this rescission is contradicted by the agency's own findings. 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 lived through multiple fire seasons in California. I saw Angeles National Forest burn. I was affected by smoke and road closures, and was evacuated from work sites because of forest fires. Friends lost access to their homes. The agency must reconcile this proposal with the ignition data in its own DEIS, which shows far higher fire density on roaded land. As a taxpayer, I object to what this proposal represents financially. The road maintenance backlog already stands at $6.9 billion. The agency's own economic analysis projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year, with a net present value ranging from -$92 million to +$199 million. The record also 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." The agency must explain how a cost-benefit analysis that cannot establish a net benefit justifies expanding a road system already in this condition. Drinking water is already a serious problem across this country, from Flint, Michigan to Appalachia. With 24 million Americans' drinking water coming from roadless areas, and with the agency's own analysis showing that roads and their facilities can produce up to 90 percent of the sediment from a timber sale, the risk to those watersheds is not speculative. Across the Southwestern region alone, 739 municipal water intakes sit in watersheds containing affected roadless areas. The agency should state plainly what its plan is to protect those intakes. The forests themselves are the resource. A home for plants and wildlife, and a place for humans to rest and recharge. Not something to extract for commodities. We have so few of these spaces left. The Native Americans believe we must consider the impact our decisions will have on the next seven generations, and this rescission would rob future Americans of places that are, as the agency's own record implies, invaluable and irreplaceable. I urge the agency to withdraw this proposal. Sincerely, Rose Shawhan Blacksburg, VA