Comment Analysis · Docket FS-2025-0001

FS-2025-0001-591345

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

In short: The comment documents that the proposed rescission of the 2001 Roadless Rule contains internal contradictions regarding forest health, underestimates cumulative economic and recreation losses, lacks specific safeguards for old-growth forests, and fails to complete required Endangered Species Act Section 7 consultations for California condors in Los Padres National Forest.

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

Environmental Protection Biodiversity
- “California condors are an Endangered Species”
- “old-growth forest, 54-63 percent is mature forest”
- “protecting roadless lands from commercial logging”
- “spread invasive plants”
Water Quality Quantity
- “protect the watersheds that sustain communities”
- “irreparable damage to western watersheds”
- “paddled the Tuolumne River”
- “watershed management”
Recreation Tourism Public Use
- “I hike in Los Padres National Forest”
- “roadless recreation is worth”
- “cumulative recreation losses over 20 years”
- “wild river at rest”
Legal Regulatory Framework
- “formal Section 7 consultation”
- “reconcile its forest-health justification with those internal findings”
- “separately analyze and disclose protections specific to old-growth stands”
- “Wilderness Act protection”

What it names

National Forests: Los Padres National Forest
Roadless areas: Tuolumne RiverWild River

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeAnalytical gapEvidenceRequestAlternativeLegal

I oppose the Forest Service's proposal to rescind the 2001 Roadless Area Conservation Rule. The Forest Service should strengthen the Roadless Rule, not eliminate it. These are OUR lands, and I am not willing to watch them handed over to road-builders, loggers, and industrial grazers without a fight. I hike in Los Padres National Forest with friends, family, and colleagues. I have paddled the Tuolumne River during the calm season to experience a wild river at rest, while other friends and family have adventured in its higher flows. As an educator in STEM with a concentration in watershed management, I understand what intact, unroaded forests actually do: they burn at lower intensity, spread fire more slowly, and protect the watersheds that sustain communities and ecosystems alike. Roads increase human-caused ignitions and spread invasive plants. Wildfire risk in Los Padres is already severe, and I oppose any action that makes it worse. The agency's forest-health rationale collapses under the weight of its own document. The proposed rule states at the Rationale for the Proposed Rule section that "The 2001 Roadless Rule limited the Forest Service’s ability to conduct vegetation management within inventoried roadless areas and has contributed to the lack of active management of the national forests, which has contributed to challenges in addressing forest health concerns." Yet the same document cites research finding the rule did not meaningfully constrain fuel treatments as a share of forested land, and states that insect and disease risk in western roadless areas is similar to or lower than on managed forest land. Those findings cannot coexist with the stated rationale. The Forest Service must reconcile its forest-health justification with those internal findings before proceeding. The agency also badly underestimates what roadless recreation is worth and what its loss would cost. The Economic Benefits from Recreation in Roadless Area Forests section states that "Assuming an upper limit of a 1 percent annual loss of economic benefit within the likely operable and likely operable but complex areas translates into potential annual losses for trail and dispersed area recreation of $4.8 million and $1.3 million for wildlife-related recreation, nationally." This figure is trivial set against roadless recreation benefits of upwards of $1.5 billion, and the same section acknowledges that the magnitude of losses is actually unknown. Roads accumulate. Settings shift and do not recover in a year. The agency must estimate cumulative recreation losses over 20 years as roads and settings change, rather than anchoring the analysis to a single-year 1 percent cap, and must compare those losses directly with projected timber revenue. In the timberland most likely to be opened by this rescission, the document itself states at the Implications for Forest Vegetation, Health, and Carbon section that "approximately 11-16 percent is old-growth forest, 54-63 percent is mature forest, and 26-31 percent is young forest." Old and mature stands together make up the overwhelming majority of what would be unlocked for harvest, yet the document identifies no old-growth-specific safeguards beyond general land management plan compliance. The Forest Service must separately analyze and disclose protections specific to old-growth stands before this land base is opened to logging. California condors are an Endangered Species found in Los Padres National Forest, where I hike, and I am deeply concerned that formal Section 7 consultation with the Fish and Wildlife Service and NOAA Fisheries has not been completed. The agency must explain how it can finalize this rescission without completing that consultation. Finally, the 2001 Roadless Rule does not address livestock grazing, a federally subsidized industry that causes irreparable damage to western watersheds and contributes less than 4% to domestic beef by the person's own account. New road construction would let harmful grazing expand further into roadless areas and would foreclose any future consideration of Wilderness Act protection for these lands. The Forest Service should prioritize voluntary grazing-permit retirement within roadless areas and close vacant allotments and allotments where grazing conflicts with roadless-area values. I want a direct response to that demand. The Forest Service should withdraw this proposed rescission and adopt a stronger national rule protecting roadless lands from commercial logging, unnecessary roads, damaging grazing, new mineral development, and motorized use.