Comment Analysis · Docket FS-2025-0001

FS-2025-0001-602891

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

In short: The comment documents that the agency's proposal to rescind the Roadless Rule conflicts with its own DEIS findings on wildfire risk, economic net benefits, and wildlife habitat protection, specifically citing DEIS Table 21 and the rejection of Alternative 3, and requests an explanation of these discrepancies and a withdrawal of the small entity certification.

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
- “wildfire argument the agency makes for rescission collapses”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “Woodchuck area is now burnt up, and I believe it should be protected from vehicles”
Economic Impact Fiscal
- “economic case for rescission does not hold together”
- “net present value spanning negative $92 million to positive $199 million”
- “Forest Service is already carrying a $6.9 billion maintenance backlog”
Wildlife Habitat
- “protect big game habitat, fisheries, and wildlife connectivity”
- “bird richness declines with road presence in forested habitat”
- “road-noise experiments in a roadless area cut bird abundance by over a quarter”
Water Quality Quantity
- “1,034 municipal water intakes sit in watersheds containing affected roadless areas”
- “hiked and ridden my bike along the Kings River, where the water is collected in reservoirs”
- “Opening these watersheds to roads for economic returns... is not a trade I accept”

What it names

National Forests: Sierra National Forest
Roadless areas: Dinkey LakesKings RiverMountain Sheep

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 places I am describing are real to me. I hike, backpack, and ride my gravel bike in the Sierra National Forest, and I have covered ground across California and west through Colorado, Arizona, New Mexico, Oregon, Washington, Idaho, Montana, Utah, Wyoming, and Nevada. I oppose the rescission of the 2001 Roadless Area Conservation Rule. The wildfire argument the agency makes for rescission collapses against its own findings. Oat Mountain needs protection from fire, and I believe people are a hazard to that area. The agency's record states this plainly: "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." I ride gravel bikes and I am familiar with the damage that motorized vehicles cause. They race around on roads and are not respectful of nature. The Woodchuck area is now burnt up, and I believe it should be protected from vehicles, not opened further to them. The Shuteye area draws the same concern. I ask that the agency explain why this proposal departs from its own prior findings, and that it reconcile the rescission with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic case for rescission does not hold together either. The agency's own 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 that, the agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year, with a net present value spanning negative $92 million to positive $199 million. The Forest Service is already carrying a $6.9 billion maintenance backlog on its road system. California alone holds 381 inventoried roadless areas totaling 4,389,760 acres, and across the Pacific Southwest region, 1,034 municipal water intakes sit in watersheds containing affected roadless areas. I have hiked and ridden my bike along the Kings River, where the water is collected in reservoirs and released as needed and the river serves both recreation and farming. Opening these watersheds to roads for economic returns the agency's own numbers cannot confirm is not a trade I accept. The agency must reconcile this proposal with a Cost Benefit Analysis that cannot establish a net benefit, and explain how expanding a road system already billions of dollars in arrears serves the public interest. I have backpacked in Dinkey Lakes. It is stunningly beautiful. We need to protect it for future generations. I watch for eagles, mountain sheep, mountain goats, bighorn sheep, birds, fish, frogs, whatever we can see. The record shows that Alternative 3 exists precisely because commenters asked the agency to protect big game habitat, fisheries, and wildlife connectivity. The agency built that alternative and then chose the one that protects none of it. On birds, the DEIS cites findings 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. The agency must say plainly why it rejected the alternative its own record built for the protection of these species, and what it proposes to substitute. The agency tried replacing the national rule with state-by-state approaches before. The record acknowledges 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 Ninth Circuit rejected that approach. The agency has not explained how this proposal avoids the same deficiencies that caused it to lose in court the last time it tried this, and that explanation is owed. Finally, the agency has certified no significant impact on small entities while its own DEIS identifies outfitters, guides, and tour operators as affected and its own Cost Benefit Analysis books a minimum recreation benefit loss of $6.1 million a year. That certification was reached by spreading losses across every small firm in the sector nationally rather than examining the specific outfitters and guides holding permits in these areas. The agency should withdraw that certification and assess the small entities actually operating in the affected roadless areas. Sincerely, Laura Fresno, CA