Comment Analysis · Docket FS-2025-0001

FS-2025-0001-591695

Opposes rescissionA3 weakSubstance 8/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment documents specific deficiencies in the agency's justification for rescinding the Roadless Rule, citing internal contradictions regarding wildfire risk data, economic cost-benefit analysis, and legal precedents from the Tenth and Ninth Circuits, while identifying specific roadless areas in California National Forests as the subject of the proposed action.

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

A3 weak: Substantive, but easier to set aside.

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.
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.
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.
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
- “Escaping to isolated sections of forest is a major part of my recreation”
- “wonderful for how accessible it remains from the greater LA area”
- “experience beauty and solitude”
- “recreation losses of at least $6.1 million a year”
Forest Management Wildfire
- “Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “reconcile the rescission with the ignition data in its own draft environmental impact statement”
- “expanding a road system already carrying a $6.9 billion maintenance backlog”
Legal Regulatory Framework
- “How does this proposal avoid the deficiencies the Ninth Circuit identified”
- “The Tenth Circuit addressed that question directly”
- “the court found the rule within the authority Congress granted”
- “on what legal basis it departs from that holding”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “timber revenue to the Forest Service of $5.2 to $11.4 million a year”
- “net present value spanning negative $92 million to positive $199 million”
- “Preserving natural beauty and places of solitude should have a higher priority than wealth extraction”

What it names

National Forests: Angeles National Forest Eldorado National Forest Inyo National Forest Los Padres National Forest
Roadless areas: Arroyo SecoPyramidSan Gabriel AddTioga Lake

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequestAlternative

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Escaping to isolated sections of forest is a major part of my recreation, and it is extremely important and valuable to me. I photograph the natural sites that inspire me: forest-covered hills and mountain peaks that are untouched, places that recall the way the land looked for thousands of years before people altered the large majority of it. The areas I am most concerned about include Sespe-Frazier in Los Padres National Forest, where I carry many fond memories of hiking and backpacking in my twenties and which is wonderful for how accessible it remains from the greater LA area; the rugged landscapes of the San Gabriel Add and Arroyo Seco units in Angeles National Forest, which provide an important escape from the nearby sprawl of LA; Pyramid in Eldorado National Forest, a wonderful place to hike and experience beauty and solitude; and Tioga Lake in Inyo National Forest, a place of immense natural beauty. California holds 381 inventoried roadless areas totaling 4,389,760 acres, and these places represent what remains. We cannot restore a landscape once it is destroyed. So little is left already, and we must save what is left for our children and further descendants. Preserving natural beauty and places of solitude should have a higher priority than wealth extraction. That is the principle I ask this agency to apply in reviewing this proposal. The agency offers wildfire management as part of the justification for rescission, but its own findings contradict that rationale. The record 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." The places I hike and photograph, these untouched forest-covered hills, carry value precisely because they have remained unroaded. I ask the agency to explain why the proposal departs from its own prior findings on fire occurrence and fuel treatment in roadless areas, and to reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic rationale fares no better on examination. The agency's own record acknowledges: "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 solitude I seek in places like Sespe-Frazier and the beauty I photograph at Tioga Lake are not abstract values; they represent the kind of recreation that the agency's own cost-benefit analysis recognizes as carrying real economic weight. The same analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year and a net present value spanning negative $92 million to positive $199 million. The agency must explain on the record how an action whose own Cost Benefit Analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog. The proposal also argues that state-specific approaches can replace a single national rule, but this ground has been tested before. The record reflects that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." California's 4,389,760 roadless acres, including the watersheds that supply 1,034 municipal water intakes across the Pacific Southwest region, were protected under the national framework precisely because local, incremental decision-making was found to gradually erode nationally significant roadless values. How does this proposal avoid the deficiencies the Ninth Circuit identified the last time the agency substituted a state-by-state approach for the national rule? Finally, the proposal contends that the 2001 rule exceeded statutory authority. But the Tenth Circuit addressed that question directly. The court found the rule within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. The agency must state plainly on what legal basis it departs from that holding. The places I have described are finite. The Pyramid roadless area covers 24,347 acres. Sespe-Frazier covers 106,910. These numbers do not grow back once a road goes in. I ask the agency to answer each of the questions raised above before proceeding further. Sincerely, Erik Krumrey San Rafael, CA