Comment Analysis · Docket FS-2025-0001

FS-2025-0001-595775

Opposes rescissionA2 moderateSubstance 10/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment documents that the agency's DEIS data shows higher human-caused fire ignition density on roaded lands, identifies a failure to quantify this risk or address road maintenance backlogs, and asserts that the regulatory flexibility analysis improperly uses national averages to certify no significant impact on small entities while ignoring specific reliance interests.

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

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 is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas”
- “reconciles a proposal framed partly around wildfire management with its own data showing that roads are the problem, not the solution”
Recreation Tourism Public Use
- “Camping with children and grandchildren is a summer tradition in our family”
- “explore further into the roadless backcountry together”
- “lost recreation benefit at a minimum of $6.1 million a year”
- “My family's expectation that this country will remain accessible and unroaded for our grandchildren to hike one day”
Governance Policy Process
- “The regulatory flexibility analysis compounds this problem”
- “The agency must withdraw the certification and assess the impact on the specific small entities operating in these areas”
- “The agency must account for the reliance interests expressed in the comments it receives”
Water Quality Quantity
- “Building roads into country that provides habitat and clean water is the opposite of how I want my money allocated”

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 Camping with children and grandchildren is a summer tradition in our family. At their current ages we only hike short trails, but I look forward to the day we can explore further into the roadless backcountry together. That future depends on keeping that country intact, and this proposal would put it at risk. The agency's own record undermines the wildfire rationale offered for rescission. The DEIS states that "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 ignition data sitting directly behind that finding is equally stark: "Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads." I want to know how the agency reconciles a proposal framed partly around wildfire management with its own data showing that roads are the problem, not the solution. The agency must quantify the expected increase in human-caused ignitions that would follow from new road access and weigh that increase honestly against any claimed reduction in wildfire hazard before proceeding further. As a taxpayer, I am very concerned about how our dollars are spent. The agency is already carrying an enormous maintenance backlog on the roads it has, and a road budget that falls far short of what is needed to address it. Building roads into country that provides habitat and clean water is the opposite of how I want my money allocated. Leave that land alone until you have fully demonstrated that you can maintain the roads already there. The proposal does not grapple with this basic stewardship question, and the agency should answer it squarely in the record. The regulatory flexibility analysis compounds this problem. "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 agency reaches its no-impact conclusion by spreading losses across every small firm in the sector nationally rather than examining the outfitters and guides who actually hold permits in the affected areas. That is not analysis; that is arithmetic arranged to avoid a finding. The agency must withdraw the certification and assess the impact on the specific small entities operating in these areas, not a national average. Finally, the agency's own notice invites comment on reliance interests. "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 expectation that this country will remain accessible and unroaded for our grandchildren to hike one day is exactly the kind of interest that expectation creates. Under the legal principles governing agency reversals, that interest must be identified and weighed, not solicited and discarded. The agency must account for the reliance interests expressed in the comments it receives, including this one. Sincerely, Sally Bartow Seattle, WA 98116