Comment Analysis · Docket FS-2025-0001

FS-2025-0001-305713

Opposes rescissionA0 noneSubstance 10/24Posted September 2, 2026 On Regulations.gov

In short: The comment establishes that the Draft EIS fails to adequately analyze impacts to endangered species, cultural properties, and water supplies, and documents the commenter's specific reliance on roadless areas in the Humboldt-Toiyabe and Inyo National Forests to support the request to select Alternative 1 (No Action).

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
- “spend a significant amount of time recreating in the roadless and backcountry areas”
- “climbing, hiking, skiing, biking and exploring in these areas”
- “quiet, undeveloped terrain that is becoming rarer every year”
- “don't want her and the next generation to miss out on the same beauty and access”
Water Quality Quantity
- “safeguarding the watersheds that supply Eastern Sierra communities”
- “source of clean water for downstream communities”
- “community water supplies that depend on undeveloped watersheds”
Environmental Protection Biodiversity
- “functioning habitat for wildlife”
- “fragment the very landscapes that currently burn less”
- “impacts to endangered species”
- “intact, unroaded backcountry”
Forest Management Wildfire
- “wildfire frequency is significantly lower in roadless areas”
- “Roads bring more human ignition sources”
- “targeted fuels treatments under existing authorities”

What it names

National Forests: Humboldt-Toiyabe National Forest Humboldt-Toiyabe National Forest Inyo National Forest Inyo National Forest
Roadless areas: Granite Chief

The comment

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

My name is Megan Mack. I am submitting this comment on the proposed rule and Draft Environmental Impact Statement regarding the 2001 Roadless Area Conservation Rule. I urge the Forest Service to select Alternative 1 – No Action, retaining the 2001 Roadless Rule in full across all 44.7 million acres of inventoried roadless areas, rather than Alternative 2 or Alternative 3. Why this matters to me personally I spend a significant amount of time recreating in the roadless and backcountry areas of the Humboldt-Toiyabe National Forest near Reno and Lake Tahoe, as well as across the Eastern Sierra in the Inyo National Forest — in particular: Mount Rose Wilderness-adjacent roadless lands (Humboldt-Toiyabe NF) — the backcountry just outside Reno, along the Nevada-California state line above Lake Tahoe. Lake Tahoe Basin roadless areas, including lands adjacent to Desolation and Granite Chief Wilderness — over 100,000 roadless acres within the Tahoe Basin Management Unit alone. Roadless forests around Mono Lake and Mammoth Lakes (Inyo NF) — roughly 32,000 acres safeguarding the watersheds that supply Eastern Sierra communities. Bishop Creek area roadless lands (Inyo NF) — the canyons and high country above Bishop, heavily used for hiking, fishing, and climbing. I have been climbing, hiking, skiing, biking and exploring in these areas with my friends for years. Now I take my daughter. I don't want her and the next generation to miss out on the same beauty and access that I have had. These are not abstract acres to me. They are the intact, unroaded backcountry that makes the country around Reno and the Eastern Sierra worth living near — the source of clean water for downstream communities, functioning habitat for wildlife, and the kind of quiet, undeveloped terrain that is becoming rarer every year across the West. Why Alternative 1 is the right choice 1. The stated rationale for rescission does not hold up. USDA has argued that new roads are needed to reduce wildfire risk. But the agency's own Draft EIS acknowledges that wildfire frequency is significantly lower in roadless areas than in roaded portions of the same forests. Roads bring more human ignition sources — vehicle sparks, campfires, target shooting, arson — and fragment the very landscapes that currently burn less. If wildfire risk reduction is the actual goal, targeted fuels treatments under existing authorities accomplish that without permanently eliminating roadless protections across 44.7 million acres. 2. The economic case is weak. Roadless areas are disproportionately steep, remote, and low-productivity for timber. Independent analyses have found that the cost of building and maintaining new roads into these areas would likely exceed the timber revenue they generate, meaning taxpayers — not industry — would absorb the difference. 3. The environmental review is incomplete. The Draft EIS does not adequately analyze foreseeable impacts to endangered species, cultural and historic properties, or community water supplies that depend on undeveloped watersheds. A rule change of this scale, affecting 44.7 million acres in 37 states, deserves a rigorous and complete analysis before any alternative other than No Action is adopted. 4. The public record already reflects overwhelming opposition. Of the more than 625,000 comments submitted during the 2025 scoping period, the overwhelming majority opposed rescission. Tribal governments consulted on this proposal have also expressed majority opposition, citing impacts to sovereignty, cultural resources, and ancestral homelands. The 2001 Rule itself was the product of the largest public input process in Forest Service history — 600 public hearings and 1.6 million comments. That record should not be discarded through a truncated rulemaking process. 5. Alternative 1 already contains reasonable flexibility. The existing rule is not absolute — it already allows exceptions for public health and safety emergencies, valid existing rights, and active mineral leases. This is a workable balance that does not require wholesale rescission to address legitimate site-specific needs. My request Please select Alternative 1 – No Action and retain the 2001 Roadless Area Conservation Rule without modification. The roadless areas of the Humboldt-Toiyabe and Inyo National Forests, and the 44.7 million acres they represent nationwide, are irreplaceable. Once roads are built and logging occurs, these areas cannot be restored to their current undeveloped condition. Thank you for considering my comment. Megan Mack