Comment Analysis · Docket FS-2025-0001

FS-2025-0001-594739

Opposes rescissionA2 moderateSubstance 12/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment documents that the agency's DEIS data on road-induced fire ignition rates contradicts the rescission rationale, identifies a failure to quantify local economic impacts on small businesses and downstream water quality risks, and requests a written explanation of how the proposal satisfies notice and participation standards given the lack of public meetings.

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
- “hike and camp in the Waterhouse, Carson-Iceberg, and Eagle roadless areas”
- “go for the quiet solitude and the wildlife”
- “children swam in a lake in the Waterhouse area”
- “appreciate the remoteness and the quietness”
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 ignition density of 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas”
- “quantify the expected increase in human-caused ignitions that would follow from new road access”
- “weigh that increase against whatever reduction in wildfire hazard it claims to achieve”
Water Quality Quantity
- “1,034 municipal water intakes sit in watersheds containing affected roadless areas”
- “depend on the filtering and stabilizing function that unroaded slopes provide”
- “Road construction disturbs those slopes”
- “downstream exposure”
Governance Policy Process
- “The regulatory flexibility analysis certifies no significant impact on small entities”
- “The agency should withdraw that certification and assess the actual small businesses”
- “The agency has also invited comment on reliance interests and then built no mechanism for weighing them”
- “how a rescission of that magnitude satisfies the notice and participation standards”

What it names

National Forests: Stanislaus National Forest

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 My husband and I hike and camp in the Waterhouse, Carson-Iceberg, and Eagle roadless areas of Stanislaus National Forest. We go for the quiet solitude and the wildlife. This summer our children swam in a lake in the Waterhouse area for the first time, and they look forward to coming back year after year. They appreciate the remoteness and the quietness. This land should be preserved as is for future generations. I am filing this comment to oppose Docket FS-2025-0001, the proposed rescission of the 2001 Roadless Area Conservation Rule. Carson-Iceberg, 56,430 acres of volcanic rock and stunning views, and Eagle, 16,116 acres, are exactly the kinds of places the rule was written to protect. We have spent time hiking in areas close to Waterhouse and Eagle that have roads, and nothing is worse than hiking and coming across part of the forest that has been clear-cut. We have been cut out from so many surrounding forest lands because private timber interests mark them to keep the public from seeing the clear cuts. It is absolutely tragic. Waterhouse, at 4,394 acres, is small enough that a single new road corridor would change its character entirely. California holds 381 inventoried roadless areas totaling 4,389,760 acres. These are not replaceable. A logged stand grows back. A road does not, at least not on any timescale that matters to the children swimming in Waterhouse lakes today. The agency frames part of its justification for rescission around wildfire and fuels management. Its own record cuts the other way. 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." The same record reports human-caused ignition density of 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas, and states that human-caused ignitions increase in abundance with proximity to roads. I ask that the agency explain why the proposal departs from these findings and how it reconciles the rescission with the ignition data its own DEIS presents. The agency should also quantify the expected increase in human-caused ignitions that would follow from new road access into areas like Eagle, Carson-Iceberg, and Waterhouse, and weigh that increase against whatever reduction in wildfire hazard it claims to achieve. That calculation belongs in the record before any final action is taken. The regulatory flexibility analysis certifies no significant impact on small entities. That conclusion cannot be squared with what sits beside it. 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 certification is reached by spreading an estimated loss across the national universe of small firms in the sector rather than examining the outfitters and guides who actually hold permits in the affected areas. The agency should withdraw that certification and assess the actual small businesses operating in these roadless areas, not a national average firm that bears none of the specific loss. The agency has also invited comment on reliance interests and then built no mechanism for weighing them. 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. My family's use of Waterhouse, Carson-Iceberg, and Eagle, our children's attachment to these places, and the expectation we formed under a rule that has been in place for over two decades are exactly the kind of interests that binding administrative law requires an agency to identify and assess when it changes course. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. Across the Pacific Southwest region, 1,034 municipal water intakes sit in watersheds containing affected roadless areas. The people downstream from Stanislaus National Forest depend on the filtering and stabilizing function that unroaded slopes provide. Road construction disturbs those slopes. The agency has not demonstrated that its proposal accounts for this downstream exposure in any concrete way, and I expect a substantive response on that point in the final record. The 2001 rule followed more than 600 public meetings and 1.6 million comments. This proposal has held none. The agency should answer, in writing, how a rescission of that magnitude satisfies the notice and participation standards that produced the original rule. Sincerely, Krista Picone Ripon, CA