Comment Analysis · Docket FS-2025-0001

FS-2025-0001-611855

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

In short: The comment establishes that the agency's proposal to rescind the 2001 Roadless Area Conservation Rule fails to reconcile its own findings on increased wildfire risk from road construction, negative net economic benefits, and prior judicial holdings regarding statutory authority, specifically within the context of the Briscoe and Reister Canyon roadless areas in Mendocino National Forest.

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, 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
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “roads increase fire risk, not reduce it”
- “Mendocino has already seen devastating losses due to climate change and wildfires”
Water Quality Quantity
- “1,034 municipal water intakes sit in watersheds containing affected roadless areas”
- “California holds 381 inventoried roadless areas totaling 4,389,760 acres”
Economic Impact Fiscal
- “agency is already $6.9 billion behind on maintaining the roads it has”
- “net present value spanning -$92 million to +$199 million”
- “recreation losses of at least $6.1 million a year”
Legal Regulatory Framework
- “Tenth Circuit held... REVERSE the district court's order”
- “Ninth Circuit found deficiencies in that approach”
- “2001 rule fell within the authority Congress granted under the Organic Act”

What it names

National Forests: Mendocino National Forest
Roadless areas: Reister Canyon
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 knowledgeAnalytical gapEvidenceRequestAlternative

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The mountain bike trails and service roads I ride run through country that has seen enough loss already. Mendocino National Forest has taken hard hits from climate change and wildfires, and the Briscoe and Reister Canyon roadless areas, 7,212 and 5,897 acres respectively, are part of what remains of a vibrant wildlife area. I am filing this comment to oppose the rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001) and to ask the agency to answer several specific questions its proposal has not adequately addressed. We need to protect and steward what little wild areas we have remaining. The Forest Service held more than 600 public meetings and took 1.6 million comments to write the rule. It has held none to undo it. 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. These are not abstractions. They are the places I ride through, the forest I know, and the inheritance I think we owe to the next generation. On the wildfire question, the agency's own 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." Mendocino has already seen devastating losses due to climate change and wildfires. It does not make sense to build roads into a wildlife area when the agency's own findings show that roads increase fire risk, not reduce it. I ask that the agency explain why this proposal departs from those prior findings and how it reconciles the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. On the economics, the agency's proposal frames rescission partly in terms of timber and energy production. The agency's own 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 is already $6.9 billion behind on maintaining the roads it has, with a road budget of roughly $73 million a year. Building new roads into country that has none, when the agency cannot maintain the roads it already has, does not make sense. 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 and a net present value spanning -$92 million to +$199 million. The agency should explain on the record how an action whose own analysis cannot establish a net benefit justifies expanding a road system already carrying that backlog. On the state-by-state approach the proposal offers as a substitute, the record before the agency states: "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 agency has tried this before. The Ninth Circuit found deficiencies in that approach. The agency should address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and explain how this proposal avoids the same deficiencies. On the authority question, the proposal suggests the 2001 rule exceeded statutory limits. The court record does not support that framing. The Tenth Circuit held: "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 agency should explain the basis for any position contrary to the Tenth Circuit's holding that the 2001 rule fell within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act, and that it did not create de facto wilderness. These are not marginal concerns. The Briscoe and Reister Canyon areas are part of what I ride through, and part of what Mendocino still has left to lose.