Comment Analysis · Docket FS-2025-0001

FS-2025-0001-267326

Opposes rescissionA3 weakSubstance 11/24Owed an answerPosted August 24, 2026 On Regulations.gov

In short: The comment documents that the proposed rescission of the 2001 Roadless Rule fails to address the anticipated negative impacts of increased unregulated off-road vehicle use and erosion resulting from new road construction, citing specific environmental evidence from the Izembek National Wildlife Refuge and Six Rivers 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

A3 weak: Substantive, but easier to set aside.

Owed an answer on Evidence.

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.
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.
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.
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

Recreation Tourism Public Use
- “negative affects of overcrowding, litter on the trails”
- “unregulated off-road use”
- “unmanaged recreation, including impacts from OHVs”
- “opportunities for solitude or primitive and unconfined recreation”
Environmental Protection Biodiversity
- “damage to the vegetation mat”
- “soil erosion, watershed and habitat degradation”
- “damage to pristine forests can not be undone”
- “transform the visual landscape of Izembek Wilderness”
Water Quality Quantity
- “disrupt hydrological processes and drainage patterns”
- “disrupt subsurface flows”
- “cause ponding and dewatering along the road corridor”

What it names

National Forests: Eldorado National Forest Six Rivers National Forest

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapLegal

As an outdoor enthusiast, I have the immense privilege of traveling to and recreate in the protected National Forests of California which is a short day trip from the major metro area where I live. I see both the beauty of the easy access to the mountains and the negative affects of overcrowding, litter on the trails, fires from illegal camping and significant erosion due to unregulated off-road use. While i see the need to "reduce regulatory burden and return land management decisionmaking for inventoried roadless areas to local Forest Service officials" (https://www.regulations.gov/document/FS-2025-0001-223869), the effects of the rescission will be more roads and doing so will cause harms the proposal simply does not address. In particular, FS-2025-0001-223869 outlines under "Summary of Potential Impacts" that Roads: "Following transportation planning, ... could be constructed for a variety of administrative or multiple use benefits, though timber harvest or other vegetation management activity would likely create the greatest need for new roads" (https://www.regulations.gov/document/FS-2025-0001-223869). The document anticipates roads in the positive sense but does not address the impact of increased unregulated use. Do we know increased roads lead to increased off-road use? Yes. Consider the Izembek National Wildlife Refuge project where the Environmental Impact Statement found: "It is highly probable that all-terrain vehicles would travel from the road into the Izembek Wilderness which would result in damage to the vegetation mat; create ruts, trails, and mud bogs; disrupt hydrological processes and drainage patterns; and increase erosion. Construction of the road would permanently introduce a physical barrier to the natural hydrologic processes of the Izembek Wilderness, and these effects would extend beyond the exchange parcel. Fill associated with the proposed road would disrupt subsurface flows, which could cause ponding and dewatering along the road corridor". — U.S. Fish and Wildlife Service, 2024 (https://www.fws.gov/sites/default/files/documents/2024-03/08-chapter-4-environmental-consequences.pdf) "Construction of a road through the existing wilderness and the predicted increase access to the wilderness via all-terrain vehicles (legal and illegal) would result in major impacts to the four indicators of wilderness character: untrammeled quality, natural quality, undeveloped quality, and opportunities for solitude or primitive and unconfined recreation. Vehicles on the road would produce noise above ambient levels (50 dBA), and these sounds would be audible within Izembek Wilderness. The proposed road would transform the visual landscape of Izembek Wilderness by introducing a road into a currently roadless area." — U.S. Fish and Wildlife Service, 2024 (https://www.fws.gov/sites/default/files/documents/2024-03/08-chapter-4-environmental-consequences.pdf) Do we expect, OHV and all-terrain vehicles to negatively affect the forest? Yes as well. "In 2004, Forest Service Chief Dale Bosworth named unmanaged recreation, including impacts from OHVs, as one of four key threats facing the nation's forests and grasslands. Unmanaged motorized use, particularly OHV use, has resulted in soil erosion, watershed and habitat degradation, spread of disease and impacts to cultural resource sites." — USDA Forest Service, Six Rivers National Forest, Gasquet Ranger District, Dece (https://www.nfwf.org/sites/default/files/norcal/Documents/SRNFEIS.pdf) While recreating in the protected wilderness of Eldorado National Forest, it is clear, all-terrain vehicle and OHV usage is popular and will continue to be. New roads will hasten this expansion and the proposed rescission of the 2001 Roadless Rule, as documented in FS-2025-0001-223869 itself anticipates these new roads. Please address this oversight before rescission of the existing rule. If the roads get built, the damage to pristine forests can not be undone. Thank you.