Comment Analysis · Docket FS-2025-0001

FS-2025-0001-327591

Opposes rescissionA0 noneSubstance 6/24Posted September 7, 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

Environmental Protection Biodiversity
- “causing watershed/habitat damage”
- “special watershed, habitat and recreational value”
- “protect wildlife habitat”
Water Quality Quantity
- “causing watershed/habitat damage”
- “special watershed, habitat and recreational value”
- “Caples Creek watershed”
Recreation Tourism Public Use
- “recreational value”
- “walking trails through granite boulder rubble”
- “Jake Schneider Meadow”
Governance Policy Process
- “just a publicity stunt, not truly a bureaucracy-reducing measure”
- “reaching consensus among the many users”
- “That is what real governing is about”

What it names

Roadless areas: Caples Creek

Attachments

1 file. Counts as 1 — Counts as one: The attachments enclose no one else's submissions; the comment counts as one.

Own letter

The comment

Do not rescind the Roadless Rule. My understanding is that the Roadless Area Conservation Rule (“Roadless Rule”) went into effect 20 years ago because the Federal government had created a mess of logging roads in the forests that were a problem because they were not being maintained and were causing watershed/habitat damage. As a small partial solution, the Roadless Rule policies were instituted to cover a small portion of the forests: the more pristine, but also more inaccessible and less readily timber-able. These areas (Inventoried Roadless Areas) were also identified as having special watershed, habitat and recreational value. One of my favorites of the Inventoried Roadless Areas is the Caples Creek Proposed Wilderness lRA located in the Eldorado Forest in Northern California. It includes the high elevation Jake Schneider Meadow and walking trails through granite boulder rubble in the Caples Creek watershed. The area survived the Caldor Fire (2021) partly because it had been prescribed burned (2019). I helped clear around the gigantic legacy trees in Caples prior to the prescribed burn (2020-05-12 Caples-Volunteer-Presentation-v3-1 for detail of this work), so that they would more likely survive the burn and most did. Some of these trees took 5 people holding hands to encircle their girth! The USDA possible action of rescinding the Roadless Rule is just a publicity stunt, not truly a bureaucracy-reducing measure. Really, the USDA should be doing everything they can to maintain and/or reduce the multitude of now unused roads in the NON-Roadless Rules areas and continue doing the very difficult work of reaching consensus among the many users of the national forests. That is what real governing is about. In any event – Do not rescind the Roadless Rule.