Comment Analysis · Docket FS-2025-0001

FS-2025-0001-297305

Opposes rescissionA0 noneSubstance 8/24Posted September 1, 2026 On Regulations.gov

In short: The comment establishes specific site-level opposition to the rescission of the 2001 Roadless Area Conservation Rule for seven named areas in California and Oregon, documenting local conditions such as road instability and fire history, and requesting a site-specific environmental analysis and a DEIS alternative that retains the rule's protections.

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

  • Wildlife Habitat
    • “Many species of wildlife need pristine areas such as these to thrive”
    • “survival of the fish and wildlife that depend on them”
    • “Roadless areas are necessary to maintain clean water... and for the survival of the fish and wildlife”
  • Water Quality Quantity
    • “maintain clean water for municipal water supplies”
    • “Roads, mining and logging are pollution sources”
    • “We don't need additional sources of pollution”
  • Recreation Tourism Public Use
    • “I hike, backpack, camp and trail run in Wilderness and Roadless Areas”
    • “These unspoiled areas are important to me”
    • “very popular area for hiking, trail running and backpacking”
  • Forest Management Wildfire
    • “Roadless Areas are not a significant impediment to fire suppression”
    • “Roadless areas tend to be healthier and more fire resistant”
    • “Most fires start along roads”

What it names

National Forests
Klamath National ForestKlamath National ForestRogue River National ForestsShasta-Trinity National Forest
Roadless areas
BoulderChips CreekGriderMcdonald PeakMcdonald PeakMt. EddyShacklefordTom Martin

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I appreciate all wildlife in these Roadless Areas. Many species of wildlife need pristine areas such as these to thrive. I hike, backpack, camp and trail run in Wilderness and Roadless Areas, mostly on the Klamath and Rogue River National Forests. These unspoiled areas are important to me. National Forests are required to be managed for multiple use. This does not mean that every acre must be roaded and logged. The best use for our remaining Roadless Areas is to remain roadless. There are abut 300.000 miles of roads in the Forest Service system. The roads on the Klamath National Forest are in terrible shape, and I suspect this is true nationally. There are more roads than the agency can maintain, and there are more roads than are necessary for administration and public use. It makes no sense to add yet more roads to a broken system. Roadless areas are necessary to maintain clean water for municipal water supplies and for the survival of the fish and wildlife that depend on them. Roads, mining and logging are pollution sources. We don't need additional sources of pollution. I am a retired wildland firefighter. In my experience, Roadless Areas are not a significant impediment to fire suppression. Roadless areas tend to be healthier and more fire resistant. They provide an opportunity to let wildland fire play its natural role in forested ecosystems. Most fires start along roads. Roadless Areas tend to be in high elevation areas, which means that they are cooler, wetter, and fires that do start there tend to be near the tops of the mountains and so are less destructive; most roadless areas on the Klamath National Forest have burned several times over the past 50 years and so are no longer burdened with unnatural fuel loads. I commented on this subject last year and never got a response. It seems that, as with many other similarly destructive projects, the agency is just going through the motions and is not seriously considering public opinion. I have been to many roadless areas, and I value both the ones I am familiar with and the ones I have never visited. To me, more roads would be a symbol of the agency's managerial, ecological, political and moral bankruptcy. There is a reason that roadless areas are roadless. They are not economically valuable for commodity production. They are not needed for motorized recreation. They have been analyzed several times over the past 50 years or so and there was never any need to road them. Nothing has changed. Leave them alone. The Pacific Crest Trail passes through the Grider roadless area, which is quite wild and scenic. The Tom Martin roadless area is near the historic Lake Mountain Lookout, which I have been to many times. I have backpacked in and around the Boulder Roadless Area. Roads in this general area have had to be abandoned because of the instability of the terrain. The Shackleford Roadless Area is adjacent to the Marble Mountains Wilderness, which I have visited many times. The Mt. Eddy roadless area is adjacent to the Pacific Crest Trail and is a very popular area for hiking and backpacking. The McDonald Peak Roadless Area is adjacent to the Pacific Crest Trail and is a very popular area for hiking, trail running and backpacking. I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule, and specifically about these inventoried roadless areas: - Grider (10,647 acres), Klamath NF, California - Tom Martin (9,031 acres), Klamath NF, California - Boulder (435 acres), Klamath NF, California - Shackleford (1,679 acres), Klamath NF, California - Mt. Eddy (7,232 acres), Shasta-Trinity NF, California Mcdonald Peak (9,431 acres), Rogue River NF, Oregon Chips Creek (42,029 acres), Plumas and Lassen National Forests, 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 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, Jeffrey Stone Yreka, CA

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