Comment Analysis · Docket FS-2025-0001

FS-2025-0001-607528

Opposes rescissionA1 strongSubstance 14/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents that the agency's proposal to rescind the Roadless Area Conservation Rule conflicts with its own DEIS data regarding increased fire ignition risks on roaded lands, fails to demonstrate a net economic benefit given the $6.9 billion road maintenance backlog, and lacks a specific on-the-record explanation for how it will protect 1,034 municipal water intakes and cold-water fish habitats in California, while also noting the procedural disparity between the 600 meetings held for the original rule and none for the rescission.

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

A1 strong: Must be answered — it names the law.

Owed an answer on Analytical gap, Evidence, Legal.

Standard dismissals it defeats

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.
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.
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.

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.
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.

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”
- “A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands”
- “mismanagement of forests leads to disastrous fires”
- “reconcile the rescission with the ignition data in DEIS Table 21”
Water Quality Quantity
- “1,034 municipal water intakes sit in watersheds containing affected roadless areas”
- “roads and their facilities can produce up to 90 percent of the sediment from a timber sale”
- “removing riparian vegetation can raise stream temperatures beyond what suits cold-water species”
- “Clean water is not a policy preference. We as humans require it.”
Economic Impact Fiscal
- “The economics do not add up, and where my tax dollars go matters to me”
- “the agency projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year”
- “expanding a road system already carrying a $6.9 billion maintenance backlog”
- “Building new roads into country that has none, while existing roads crumble, is not a responsible use of public funds”
Legal Regulatory Framework
- “The Tenth Circuit spoke plainly: 'Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order'”
- “The court held the 2001 rule was within the authority Congress granted under the Organic Act and MUSYA”
- “The agency owes the public a specific, on-the-record explanation of its basis for any contrary legal position”

What it names

National Forests: Angeles National Forest San Bernardino National Forest
Roadless areas: Cucamonga C
Law cited: 28 U.S.C. Section 1291

The comment

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

Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Hunting since I was 10 years old has connected me to the cycle of life, to my food, to how it is processed and where it comes from. The national parks and forests have been my refuge in hectic times, my place of peace. I have been a trail guide in 5 states, led hikes through the Angeles National Forest and San Gabriel wilderness, through the Cascade Mountains, climbed Mount Rainier, and led hunting trips through the Alaskan wilderness. I have photographed Big Horn Mine, the surrounding mountains, and the San Gabriel wilderness. I want my children to have the same opportunities I had to explore and appreciate these lands. I oppose rescission of the 2001 Roadless Area Conservation Rule. The agency's own data on wildfire should stop this proposal in its tracks. The record 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." I have lived through several major wildfires, some that nearly took our home. I know that mismanagement of forests leads to disastrous fires, which then cause sudden flash floods when it rains. The agency is now proposing to open roadless areas in the name of fire management while its own record shows that roading those areas increases ignition risk. I ask the agency to explain why this proposal departs from its own prior findings and to 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 economics do not add up, and where my tax dollars go matters to me. The record states: "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." The agency projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year, and the net present value of the proposal spans -$92 million to +$199 million. The agency cannot establish a net benefit, yet it proposes expanding a road system already carrying a $6.9 billion maintenance backlog on a road budget of about $73 million a year. Building new roads into country that has none, while existing roads crumble, is not a responsible use of public funds. The agency must reconcile this proposal with those numbers and explain on the record how that arithmetic serves the public interest. One of my first memories of fishing is on the American River that flows through Sacramento, pulling salmon in almost as big as me at the time. California 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. The agency's own analysis acknowledges that roads and their facilities can produce up to 90 percent of the sediment from a timber sale, and that removing riparian vegetation can raise stream temperatures beyond what suits cold-water species, reducing egg survival, rearing densities and growth of coho salmon in areas that include Essential Fish Habitat and critical habitats managed by NMFS. The Cucamonga A unit of 1,249 acres in the Angeles National Forest and the Cucamonga C unit of 4,106 acres in the San Bernardino National Forest sit in this landscape. Clean water is not a policy preference. We as humans require it. Our wildlife and forests need it. I want the agency to tell me, specifically, how it intends to protect those 1,034 intake watersheds if this rule falls. On the question of statutory authority, the Tenth Circuit spoke plainly: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The court held the 2001 rule was within the authority Congress granted under the Organic Act and MUSYA and did not create de facto wilderness. The agency owes the public a specific, on-the-record explanation of its basis for any contrary legal position. The Forest Service held more than 600 public meetings and took 1.6 million comments to write this rule. It has held none to undo it. Our lands should be kept and managed for future generations. Their loss will have an unimaginable impact on us all. Sincerely, John Benge Chino, CA