Comment Analysis · Docket FS-2025-0001

FS-2025-0001-605213

Opposes rescissionA3 weakSubstance 8/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment establishes that the proposed rescission is arbitrary and capricious because the DEIS data contradicts the agency's stated goal of reducing wildfire risk by showing that road construction increases fire incidence and that roadless areas already receive comparable fuel treatments.

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

A3 weak: Substantive, but easier to set aside.

Owed an answer on Analytical gap, Evidence.

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.
Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
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.
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.

Topics

Forest Management Wildfire
- “reducing wildfire risk is in fact contradicted by the data”
- “bringing roads into intact forests in fact increases fires”
- “90% of US wildfires start within half a mile of a road”
- “inventoried roadless areas have already had wildfire risk addressed”
Legal Regulatory Framework
- “nonsensical, arbitrary and capricious”
- “legally unsound, arbitrary, capricious, an abuse of discretion”
- “not in accordance with law”
- “should be immediately withdrawn”
Environmental Protection Biodiversity
- “biota would fall victim to the proposed action”
- “private plunder which is its point”
- “frequent visitor to federal public lands”

What it names

National Forests: Mendocino National Forest

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequest

This comment comes to you from an incensed member of the public. I am a US citizen and resident, a frequent visitor to federal public lands, and own property within some 30 linear miles - within the smoke/air quality, regulatory, and insurance impact zone - of the Mendocino National Forest. I have a lifetime of residence and outdoor recreation in three West Coast states whose biota would fall victim to the proposed action and the private plunder which is its point. The proposed rescission is nonsensical, arbitrary and capricious. Its primary stated goal of reducing wildfire risk is in fact contradicted by the data in its DEIS which notes, for example that bringing roads into intact forests in fact increases fires; 90% of US wildfires start within half a mile of a road; and inventoried roadless areas have already had wildfire risk addressed by treatment such as pile burning, tree cutting, and chipping at rates that are similar to other national forest lands. Because the proposal if implemented would in fact thwart its declared key goal and instead increase wildfires, the proposal is nonsensical, legally unsound, arbitrary, capricious, an abuse of discretion, and otherwise not in accordance with law; and should be immediately withdrawn.