Comment Analysis · Docket FS-2025-0001

FS-2025-0001-284590

Opposes rescissionA0 noneSubstance 8/24Posted August 28, 2026 On Regulations.gov

In short: The comment establishes that the DEIS fails to demonstrate that rescinding the 2001 Roadless Area Conservation Rule reduces wildfire risk, citing data that fewer than 1% of wildfires start in roadless areas and that fires are four times more likely near roads, while asserting the commenter's standing as a resident of Carmichael, California, and user of specific recreation areas in the Tahoe and northern Sierra regions.

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

A0 none: Counted, not answered.

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.
Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
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.
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.

Topics

Recreation Tourism Public Use
- “lifelong outdoor recreationist”
- “preserve an undeveloped backcountry experience”
- “permits mountain biking, climbing, and a broad range of human-powered recreation”
- “protects about 25,121 miles of trail, 8,659 climbing routes”
Forest Management Wildfire
- “DEIS does not establish that rescission reduces that risk”
- “Fewer than 1% of wildfires in the lower 48 states since 2010 have started in roadless areas”
- “fires are roughly four times more likely to start near a road”
- “existing rule already contains exceptions for public health and safety emergencies”
Environmental Protection Biodiversity
- “retain the 2001 Roadless Area Conservation Rule without modification”
- “Rescission does not move these lands into a stricter category”
- “A road, once cut, is permanent in practical terms”
- “decision to leave a landscape roadless can always be revisited”

What it names

National Forests: Eldorado National Forest Lake Tahoe Basin Management Unit Tahoe National Forest

The comment

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

I am writing to urge the Forest Service to select Alternative 1 and retain the 2001 Roadless Area Conservation Rule without modification. I am a resident of Carmichael, California, and a lifelong outdoor recreationist. I camp, hike, rock climb, paddle, snowboard, snowshoe, and mountain/road bike, most often in the Tahoe and northern Sierra region, where I take my family several times a year. The inventoried roadless areas on the Tahoe National Forest, Eldorado National Forest, and Lake Tahoe Basin Management Unit are not abstractions to me. They include ground near Echo Lakes, the country skirting Desolation Wilderness, portions of the Tahoe Rim Trail, and Freel Peak. Roadless areas matter to me for a reason I think gets lost in this debate: they are not Wilderness. Designated Wilderness excludes bicycles and limits some of the ways my family uses public land. Inventoried roadless areas preserve an undeveloped backcountry experience while still permitting mountain biking, climbing, and a broad range of human-powered recreation. Nationally, the rule protects about 25,121 miles of trail, 8,659 climbing routes, 768 miles of whitewater, and 10,794 miles of mountain biking. Rescission does not move these lands into a stricter category. It removes the only protection they have. I take the wildfire rationale seriously, having lived through half a decade of Sacramento Valley smoke seasons. But the DEIS does not establish that rescission reduces that risk. Fewer than 1% of wildfires in the lower 48 states since 2010 have started in roadless areas, and the proposed rule anticipates permanent roads across 18.2 million acres and temporary roads across another 11.3 million. Research indicates fires are roughly four times more likely to start near a road than in roadless forest. Roads bring vehicles, and vehicles bring ignitions. The existing rule already contains exceptions for public health and safety emergencies. Where a specific fuels treatment is genuinely warranted, those exceptions and site-specific NEPA review are the appropriate tools. A nationwide rescission is not. California holds roughly 4.4 million acres of inventoried roadless area across 21 national forests, the third-largest total of any state. The time and money my family spends in Truckee, Kings Beach, Tahoe City, and South Lake Tahoe flows to those communities specifically because the backcountry behind them is intact. Alternative 2 forecloses something that cannot be restored on any human timescale. A road, once cut, is permanent in practical terms. A decision to leave a landscape roadless can always be revisited. That asymmetry should weigh heavily in the record of decision. I urge the Forest Service to adopt Alternative 1.