Comment Analysis · Docket FS-2025-0001

FS-2025-0001-256664

Opposes rescissionA1 strongSubstance 13/24Owed an answerPosted August 23, 2026 On Regulations.gov

In short: The comment establishes that the rescission of the Roadless Area Conservation Rule would have significant site-specific environmental consequences, particularly regarding water quality and sedimentation impacts on public drinking water sources.

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

Water Quality Quantity
- “Clean water is a basic human right”
- “Tuolumne River is the headwaters for the fresh drinking water of 2.7 million Americans”
- “Road sediment is quantified and then set aside”
- “Unmaintained roads damage water, by the agency's own admission”
Environmental Protection Biodiversity
- “pristine, free-flowing Wild and Scenic River”
- “vital ecosystem habitats for countless species”
- “loss of clean water”
- “Roads lead to ruin”
Governance Policy Process
- “Not one county, one state, nor even one region possesses the right to decide on behalf of all of us”
- “infected with billionaires, shamelessly self-dealing”
- “ask that the agency disclose and analyze the site-specific environmental consequences”
- “ask that the agency respond in the record to each of the issues”

What it names

National Forests: Stanislaus National Forest Tahoe National Forest
Roadless areas: Middle ForkNorth Fork Middle Fork American RiverTuolumne River
Law cited: 36 CFR 294.12

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeAnalytical gap

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Clean water is a basic human right, not a privilege. Clean water is fundamental to the health and well being of all living things. We sacrifice this precious resource at our own peril, and of future generations. With the thousands of miles of backcountry roads in existence, there is no new road for logging or mining or purportedly to reduce wildfires, that our children would choose as a their legacy if it comes at the loss of clean water. Quite simply, water is life. Roads lead to ruin. PUBLIC land is a PUBLIC good. It is managed on behalf of EVERY tax payer in America, today, those who fought for it before, and those who will inherit it in the future. Not one county, one state, nor even one region possesses the right to decide on behalf of all of us what is in OUR best interest. And certainly not one low approval administration, infected with billionaires, shamelessly self-dealing their way to greater wealth at everyone else's expense. The Tuolumne River is the headwaters for the fresh drinking water of 2.7 million Americans from the Central Valley to San Francisco. Its vitality is elemental to the health and well being of a large portion of the a state that is the fourth largest economy in the world. The North Fork Middle Fork of the American River remains nationally significant as a pristine, free-flowing Wild and Scenic River that offers world-class recreation and vital ecosystem habitats for countless species. I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule, and specifically about these inventoried roadless areas: - Tuolumne River (17,217 acres), Stanislaus NF, California - North Fork Middle Fork American River (11,245 acres), Tahoe NF, California I ask that the agency disclose and analyze the site-specific environmental consequences of the proposed rescission for each of these areas, including the effects of the road construction and timber harvest it would newly allow. I raise the following issues for the record and ask that the agency respond to each of them: Issue 1: Twenty-four million people’s drinking water is asserted away Clean water matters to me, and my own tap may trace back to this country. I do not accept assurances in place of analysis. Approximately 24 million people use water originating within the potentially affected roadless areas, through more than 7,000 municipal intakes, and less than 12 percent of these watersheds are currently impaired. The DEIS says forest plans address sources of public drinking water without identifying one enforceable provision. I ask that the agency identify, forest by forest, which plan provisions are equivalent to 36 CFR 294.12 and 294.13 for municipal watersheds. Issue 2: Road sediment is quantified and then set aside Clean water matters to me, and sediment is not an abstraction when it is headed for water people drink. The agency quantifies the risk and then walks away from it. The DEIS: skid roads, trails, log landings and similar disturbances within timber sale areas are the main cause of soil erosion and “can contribute up to 90 percent of the sediment generated by timber sale activity.” The number appears in the document; no projection of sediment delivery follows it. I ask that the agency quantify projected sediment delivery to the more than 7,000 municipal intakes downstream of these areas. Issue 3: Unmaintained roads damage water, by the agency’s own admission Clean water matters to me, and roads nobody maintains do not stay harmless. The agency admits as much in its own analysis. “Lack of maintenance commonly has detrimental effects on water quality. Insufficient maintenance funding is a key reason for the lack of adequate road maintenance.” The same document proposes adding road mileage against a maintenance shortfall it identifies as a cause of water quality damage. I ask that the agency reconcile the proposed increase in road mileage with the maintenance shortfall its own analysis identifies as a water quality cause. I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule’s protections for the areas named above. Where this proposal rests on factual conclusions that differ from the agency’s own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record. Sincerely, Scott Crocker Berkeley, California