Comment Analysis · Docket FS-2025-0001

FS-2025-0001-308103

Opposes rescissionA0 noneSubstance 4/24Posted September 3, 2026 On Regulations.gov

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
    • “fragment essential habitat for wildlife”
    • “wildlife requiring untrammeled environments”
    • “retain their roadless character”
  • Environmental Protection Biodiversity
    • “facilitate the spread of invasive species”
    • “safeguard these vital ecosystems”
    • “severe soil erosion”

What it names

National Forests
Sequoia National ForestShasta-Trinity National ForestSierra National ForestSix Rivers National Forest

The comment

As a wildlife biologist, I have surveyed areas managed under the 2001 Roadless Rule in Six Rivers National Forest, Shasta-Trinity National Forest, Sierra National Forest, and Sequoia National Forest. It is critical that these lands retain their roadless character. Roads cause severe soil erosion, facilitate the spread of invasive species, and fragment essential habitat for wildlife requiring untrammeled environments. I strongly encourage the USDA Forest Service to retain the full protections afforded under Alternative 1 to safeguard these vital ecosystems.

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