Comment Analysis · Docket FS-2025-0001

FS-2025-0001-593290

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

In short: The comment documents the commenter's personal displacement by the Eaton Fire and Angeles National Forest as the specific location of impact, while citing the agency's own EIS data on fire density, sediment production, and cost-benefit figures to highlight gaps in the agency's analysis regarding wildfire risk, water quality, and economic justification for the rescission.

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

Forest Management Wildfire
- “human-caused or wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “preserving native wildlife and old growth that protect against fire”
- “fire moves through degraded, roaded terrain”
Water Quality Quantity
- “Water is a sacred source”
- “roads and their facilities can produce up to 90 percent of the sediment from a timber sale”
- “communities drinking water that starts in these roadless watersheds”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “recreation losses of at least $6.1 million a year”
- “road system already carrying a $6.9 billion maintenance backlog”
Legal Regulatory Framework
- “Tenth Circuit already addressed that question”
- “Ninth Circuit identified deficiencies in the state-by-state approach”
- “rule within the authority Congress granted under the Organic Act”

What it names

National Forests: Angeles National Forest
Law cited: 28 U.S.C. Section 1291

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 Eaton Fire displaced me from my home for over one year, and I did not return. That experience is inseparable from why I oppose this rescission. Our resources should not be used to deforest our land. They should be directed toward the indigenous communities that have long cared for this land in historically scientific and ecological ways, preserving native wildlife and old growth that protect against fire. Opening roadless areas to roads and the activity that follows moves in exactly the opposite direction. On the wildfire question, the agency's own 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 or wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." Angeles National Forest, one of the many pristine ecosystems at stake here, sits in the middle of this reality. Bobcats to beetles depend on it, and so do the communities whose homes and lives are threatened when fire moves through degraded, roaded terrain. The agency must explain why this proposal departs from those prior findings and 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. Water is a sacred source, and any damage to our current watersheds will not go unnoticed. The agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale. The communities drinking water that starts in these roadless watersheds are not abstractions. The agency should be required to answer, on the record, how it weighs that contamination risk against whatever benefit it projects from opening these areas. The projected benefit is itself difficult to square. The agency's 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." Against those figures, the agency's own cost-benefit analysis projects timber revenue of $5.2 to $11.4 million a year to the Forest Service, recreation losses of at least $6.1 million a year, and a net present value spanning -$92 million to +$199 million. A road system already carrying a $6.9 billion maintenance backlog would be expanded by a proposal whose own numbers cannot establish a net benefit. The agency must reconcile those figures and explain what economic justification supports this action. The proposal also argues for replacing the national rule with state-specific approaches, yet the record itself records 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. The agency tried that path before. The Ninth Circuit identified deficiencies in the state-by-state approach the last time it was attempted. The agency must address its own prior finding that local decision-making can incrementally reduce nationally significant roadless values and explain how this proposal avoids the same result. Finally, the proposal argues that the 2001 rule exceeded the agency's statutory authority. The Tenth Circuit already addressed that question and held: "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 court found the rule within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not find that it created de facto wilderness. What legal basis does the agency now advance for a contrary position, and how does it distinguish that holding? I hike with my dog, camp in the mountains, and rock climb in places like Angeles National Forest because they are still intact. I oppose this rescission and urge the agency to withdraw it. Sincerely, Rebecca Seman Tujunga CA