Comment Analysis · Docket FS-2025-0001

FS-2025-0001-608861

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

In short: The comment establishes that the agency's DEIS fails to quantify the projected increase in human-caused wildfires and biodiversity loss from road access, relies on a flawed national average for the regulatory flexibility analysis, and ignores specific reliance interests and water intake dependencies in the affected roadless areas.

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.

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
- “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”
- “human-caused ignitions increase in abundance with proximity to roads”
- “road access could increase the number and frequency of wildfires”
- “quantify the expected rise in human-caused ignitions that new road access would produce”
Environmental Protection Biodiversity
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
- “no projection of what that fragmentation would mean across the 40.1 million acres of potentially affected environment”
- “Wildlife that our family has spent generations learning to find and understand”
- “apply the cited fragmentation range to the 40.1 million acres of potentially affected environment”
Water Quality Quantity
- “watershed protections that serve the 1,034 municipal water intakes”
- “sitting in watersheds containing affected roadless areas”
- “measured in drinking water rather than recreation”
- “belong in the analysis”
Recreation Tourism Public Use
- “Four generations of our family have dispersed camped in California's national forests”
- “Teaching our children and grandchildren about the remarkable wildlife”
- “lost recreation benefit at a minimum of $6.1 million a year”
- “structured decades of outdoor life around the understanding that these forests would remain intact”

What it names

National Forests: Tahoe National Forest
Roadless areas: North Fork Middle Fork American River

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 Four generations of our family have dispersed camped in California's national forests. Teaching our children and grandchildren about the remarkable wildlife found in places like the North Fork Middle Fork American River roadless area in the Tahoe National Forest is not a casual habit for us; it is how we pass on something we care about deeply. When the Forest Service proposes to rescind the 2001 Roadless Area Conservation Rule, it proposes to change the terms under which we have lived on this land across a span of lifetimes, and I oppose that rescission in the strongest terms I am able to put on paper. The agency's own data on fire risk undermines the case for opening these areas. The DEIS states exactly this: "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." That is not a peripheral finding buried in an appendix; it is the agency's own decade-long record, drawn from the proposal's own supporting document. The North Fork Middle Fork American River, like the rest of California's 4,389,760 acres across 381 inventoried roadless areas, currently benefits from the fire suppression that low road density provides. The effects analysis concedes that road access could increase the number and frequency of wildfires, yet no projection of that increase is offered. I ask that the agency quantify the expected rise in human-caused ignitions that new road access would produce and weigh it explicitly against whatever claimed reduction in wildfire hazard the proposal asserts. The biodiversity our family values in these places is also placed at risk in a way the agency acknowledges numerically but refuses to apply. "The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent." That range is broad and the lower bound alone is significant; the upper bound is severe. Yet no projection of what that fragmentation would mean across the 40.1 million acres of potentially affected environment appears anywhere in the analysis. Wildlife that our family has spent generations learning to find and understand in California's national forests is represented in the DEIS only as a statistic borrowed from elsewhere and never applied to the landscape at stake. I ask that the agency apply the cited fragmentation range to the 40.1 million acres of potentially affected environment and publish that projection as part of its final analysis. The regulatory flexibility analysis that accompanies this proposal cannot survive scrutiny. "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 no-impact conclusion is reached by distributing a $9 million annual expenditure loss across every small firm in the sector nationwide rather than examining the outfitters and guides who actually hold permits in the affected areas, and the analysis concedes that some firms may lose those receipts entirely. A certification reached by that method does not satisfy the purpose of the regulatory flexibility process. The agency must withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. Finally, reliance matters here, and the agency has not attempted to measure it. "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." This comment is one such interest. Our family has structured decades of outdoor life around the understanding that these forests would remain intact. The watershed protections that serve the 1,034 municipal water intakes sitting in watersheds containing affected roadless areas across the Pacific Southwest region, which includes California, represent a different order of reliance, one measured in drinking water rather than recreation, but both belong in the analysis. The agency invited these statements and owes an accounting: it must identify and weigh the reliance interests described in the comments it receives, including this one, before any final rule is issued. We want these lands managed responsibly to ensure lasting prosperity. That is not a slogan; it is the standard we have applied across four generations, and it is the standard the agency should apply here. Sincerely, Matthew Keene Somerset, Ca