Comment Analysis · Docket FS-2025-0001

FS-2025-0001-599803

Opposes rescissionA2 moderateSubstance 13/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents that the agency's DEIS and Cost Benefit Analysis contain internal contradictions regarding wildfire ignition rates, bird abundance declines, and small entity impacts, and asserts that the commenter's reliance interests in the 2001 Roadless Rule were solicited but not assessed.

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

Wildlife Habitat
- “bird richness declines with road presence”
- “road-noise experiments... cut bird abundance by over a quarter”
- “largest concentration of shorebirds in the Western Hemisphere”
- “Bald eagles, trumpeter swans, brown bear, moose, and mountain goat depend on this landscape”
Recreation Tourism Public Use
- “Backpacking and hiking... to commune with nature”
- “impact of roads and off road vehicles on... the experience being in the 'wilderness'”
- “lost recreation benefit at a minimum of $6.1 million a year”
- “My years of hiking, birding, and backpacking in California's roadless areas”
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”
- “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 from new road access”
Legal Regulatory Framework
- “The regulatory flexibility certification also cannot stand as written”
- “agency certifies no significant impact on small entities while its own DEIS names outfitters, guides, and tour operators as affected”
- “A state-petition process substituted for a national rule creates no guarantee that protection continues”
- “reliance interests in the current rule that could be affected by this proposal”

What it names

National Forests: Chugach National Forest Inyo National Forest
Roadless areas: Paiute

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 Backpacking and hiking through places like Pyramid in the Lake Tahoe Basin and the Paiute roadless area in Inyo National Forest to commune with nature, watch birds, and observe wildlife, I have come to understand what these landscapes hold. Rescinding the 2001 Roadless Area Conservation Rule would put that at risk, and the agency's own analysis does not support the step it is proposing to take. I am an avid backpacker and day hiker who lives in Northern California. I have travelled all over the United States to hike and backpack. The impact of roads and off road vehicles on wildlife, the land and the experience being in the “wilderness” is obvious and depressing. Bird watching is not incidental to why I go into roadless areas. It is a central reason. The agency's own record, drawing on research the DEIS cites, documents that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. California already holds 381 inventoried roadless areas totaling 4,389,760 acres, and the birds I go to find depend on the quiet and the unbroken canopy those areas provide. Opening that landscape to road-building does not simply alter the scenery. It restructures the acoustic and ecological conditions that determine whether those species stay or go. I ask the agency to explain, with specificity, how the benefits it claims from rescission can be weighed against documented declines in bird abundance and species presence that its own cited science predicts. The wildfire rationale the agency offers for this rescission conflicts directly with what its own record says. 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 DEIS further 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. The agency must explain why its proposal departs from these findings, reconcile the rescission with the ignition data in DEIS Table 21, and quantify the expected increase in human-caused ignitions from new road access weighed against any claimed reduction in wildfire hazard. The regulatory flexibility certification also cannot stand as written. The agency certifies no significant impact on small entities while its own DEIS names outfitters, guides, and tour operators as affected, and its Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. That certification is reached by spreading expenditure loss across every small firm in the sector nationally rather than examining the guides and outfitters holding permits in the specific affected areas. The agency concedes some firms may lose those receipts. It should withdraw the certification and assess impact on the small entities actually operating in and permitted for the potentially affected roadless areas. The Chugach National Forest in Alaska is the most roadless national forest in the entire system. Ninety-nine percent of it has never had a road built through it. It holds 40 inventoried roadless areas totaling 5,439,110 acres. The Copper River Delta within it hosts the largest concentration of shorebirds in the Western Hemisphere during spring migration, including western sandpiper in the millions. Bald eagles, trumpeter swans, brown bear, moose, and mountain goat depend on this landscape at a scale that exists nowhere else in the national forest system. The 2001 rule is the structural protection that has kept those conditions intact. A state-petition process substituted for a national rule creates no guarantee that protection continues, and the agency's own record does not model what happens to that ecosystem if the rule falls. Finally, the proposal itself 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 years of hiking, birding, and backpacking in California's roadless areas, and my expectation that federal policy would continue to protect them, are exactly the kind of reliance interests the agency invited and then declined to assess. The agency must identify and weigh those interests as part of this proceeding, including what this comment represents. Sincerely, Kristen Sorensen Petaluma, CA