Comment Analysis · Docket FS-2025-0001

FS-2025-0001-611940

Opposes rescissionA1 strongSubstance 15/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment establishes that the proposed rescission of the Roadless Area Conservation Rule contradicts the agency's own data on wildfire ignition risks and economic costs, specifically citing DEIS Table 21 and Cost Benefit Analysis figures, and requests specific on-record explanations regarding water quality protection for 1,034 municipal intakes and the reconciliation of the $6.9 billion road maintenance backlog.

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

Wildlife Habitat
- “California Condors soaring over the Los Padres National Forest”
- “mountain lions, badgers, kangaroo rats, and arroyo toads”
- “Sespe-Frazier Roadless Area... acts as a critical buffer zone to the Sespe Wilderness and condor sanctuary”
Water Quality Quantity
- “The White Ledge watershed and its habitat would face exactly this elevated ignition risk”
- “1,034 municipal water intakes sit in watersheds containing affected roadless areas”
- “Roads degrade water quality”
Recreation Tourism Public Use
- “raw wild places I seek out on foot, by bike, and with a camera”
- “explored on foot and by bike on trails including Cold Springs and Boulder Canyon”
- “recreation losses of at least $6.1 million per year”
Economic Impact Fiscal
- “The economic justification for this rescission is not sustained by the agency's own numbers”
- “road system already carrying a $6.9 billion maintenance backlog”
- “net present value ranging from -$92 million to +$199 million”

What it names

National Forests: Los Padres National Forest
Roadless areas: Boulder CanyonWhite Ledge
Law cited: 36 C.F.R. Section 294.12

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 The California Condors soaring over the Los Padres National Forest, the mountain lions, badgers, kangaroo rats, and arroyo toads I have spent years observing in roadless areas throughout that forest, and the raw wild places I seek out on foot, by bike, and with a camera to capture canyons, watersheds, meadows and mountains unmarked by roads, are all directly threatened by the proposal to rescind the 2001 Roadless Area Conservation Rule. I am filing this comment in opposition to Docket FS-2025-0001. The White Ledge Roadless Area, all 18,632 acres of it, is the closest roadless area to where I live and have grown up. It is a place I have admired from afar for my whole lifetime and, more recently, explored on foot and by bike on trails including Cold Springs and Boulder Canyon. Much of what characterizes White Ledge is the lack of roads, and the agency's own record speaks directly to what roads would bring. The agency has stated: "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." The White Ledge watershed and its habitat would face exactly this elevated ignition risk the moment road construction begins. The proposal justifies rescission in part on wildfire and fuels management grounds, yet it departs from its own prior findings. I ask that the agency explain, in plain terms responsive to the record, why the rescission contradicts its own ignition data, including the fire density comparisons reported in DEIS Table 21, which show far higher fire density on roaded land than inside affected roadless areas. The Sespe-Frazier Roadless Area covers 106,910 acres, acts as a critical buffer zone to the Sespe Wilderness and condor sanctuary, and supports recreation and tourism throughout my neck of the woods. California condors have little margin for error, and neither does this landscape. California holds 381 inventoried roadless areas totaling 4,389,760 acres, and across the Pacific Southwest region, which includes California, 1,034 municipal water intakes sit in watersheds containing affected roadless areas. Roads degrade water quality; I have said that plainly with respect to White Ledge and the principle holds no less for Sespe-Frazier. The agency should be required to explain on the record how water quality across those 1,034 intake watersheds is protected under this proposal. The economic justification for this rescission is not sustained by the agency's own numbers. 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's own Cost Benefit Analysis projects timber revenue of $5.2 to $11.4 million per year against recreation losses of at least $6.1 million per year, with a net present value ranging from -$92 million to +$199 million. That range cannot establish a net benefit. The agency must reconcile this proposal with a road system already carrying a $6.9 billion maintenance backlog and explain how adding roads to places like the trails I ride, including Oceanview, Franklin, Romero, Gridley, Middle Sespe and others throughout the Los Padres, is fiscally responsible when the numbers in its own analysis do not close. On the question of replacing a national rule with state-by-state approaches, the agency's own record 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 Ninth Circuit has already examined that logic and found it wanting the last time the agency pursued this path. The agency must address, specifically and on the record, how this proposal avoids the deficiencies the Ninth Circuit identified in the prior state-by-state attempt, and how local decision-making will not incrementally reduce nationally significant roadless values in ways that cannot be undone. Finally, the rescission is framed in part as a response to administrative and permitting burdens, yet the rule as written already provides that it "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." Before eliminating protections that give places like White Ledge and Sespe-Frazier their character, the agency must identify with specificity which burdens are not already handled by these existing exceptions, and quantify them. Sincerely, Ben Van Der Kar Carpinteria, CA