Comment Analysis · Docket FS-2025-0001

FS-2025-0001-345211

Opposes rescissionA1 strongSubstance 16/24Owed an answerPosted September 12, 2026 On Regulations.gov

In short: The comment places on the record specific deficiencies in the agency's analysis regarding big game population projections, sediment loading impacts on 1,466 municipal water intakes, and wildfire ignition risks, while citing the agency's own prior findings and regulatory text to argue that the rescission of the 2001 Roadless Area Conservation Rule fails to address these environmental and legal concerns.

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

A1 strong: Must be answered — it names the law.

Owed an answer on Analytical gap, Evidence, Legal.

Standard dismissals it defeats

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

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.
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.
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.

Topics

Wildlife Habitat
- “having areas where animals can be unbothered is important for population growth”
- “elk survival rates increased during a road closure and decreased when the gates were removed”
- “elk avoid roads and select unroaded habitat”
- “project what this proposal does to big game populations”
Water Quality Quantity
- “1,466 municipal water intakes sit in watersheds containing affected roadless areas”
- “drinking water crisis has been an issue my entire life”
- “roads and their facilities can produce up to 90 percent of the sediment from a timber sale”
- “explain what protections replace the rule's watershed safeguards”
Recreation Tourism Public Use
- “Hunting is a generational tradition in my family”
- “Losing the wildness of that area by allowing roads to be introduced puts it at risk”
- “environments suffer from people who are not educated in outdoor recreation”
- “Being able to share these places with my children is important to me”
Forest Management Wildfire
- “Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “Adding roads increases ignition risk by the agency's own measure”
- “explain in the record why it departs from its own prior findings on fire occurrence”

What it names

National Forests: Humboldt-Toiyabe National Forest
Roadless areas: Charleston - Macks CynCurrant - Duckwater BCurrant - East SlopeLa Madre - Prospect
Law cited: 36 C.F.R. Section 294.12

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 Hunting is a generational tradition in my family. Having truly wild areas where we can exercise our right to provide for our family matters deeply to us, and having areas where animals can be unbothered is important for population growth. The Copper Mountains roadless area in Humboldt-Toiyabe National Forest, 31,945 acres of it, has become a significant place to my family. Losing the wildness of that area by allowing roads to be introduced puts it at risk. I oppose the rescission of the 2001 Roadless Area Conservation Rule under Docket FS-2025-0001, and I ask the agency to respond to the following concerns. The agency's own record states: "The DEIS cites the finding that elk survival rates increased during a road closure and decreased when the gates were removed (Cole 1997), and that elk avoid roads and select unroaded habitat.". It goes directly to what my family depends on in the Copper Mountains and in the other roadless areas of the Humboldt-Toiyabe. No population-level effect on big game is projected anywhere in the rescission document. The agency must project what this proposal does to big game populations and hunter opportunity, and provide that projection in the record before any final decision is made. I have fished Lake Mead for many many years, and I have watched what happens when human activity increases. The shorelines get filthier and illegal roads increase, and that is a National Recreation Area with rangers constantly patrolling. The areas that would lose roadless protection are not patrolled that way. Opening protected areas would lead to increased pollution from vehicle emissions. Across the Intermountain region, which includes Nevada, 1,466 municipal water intakes sit in watersheds containing affected roadless areas. The drinking water crisis has been an issue my entire life here in southern Nevada, and the agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale. The agency must explain what protections replace the rule's watershed safeguards and how sediment loading at those 1,466 intakes is addressed in the record. The proposal claims that state-specific approaches can substitute for a national rule. The record itself states: "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." That argument has been made before and the courts rejected it. I ask the agency to address its own prior finding that local decision-making can incrementally reduce nationally significant roadless values, and to explain how this proposal avoids the deficiencies the Ninth Circuit identified the last time the agency replaced the national rule with a state-by-state approach. The agency also argues the rule imposes permitting and administrative burdens. But the rule's text shows: "It generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." The burden argument requires the agency to identify which specific burdens are not already addressed by these existing exceptions, including those for public health and safety and community wildfire protection, and to quantify those burdens in the record rather than assert them in general terms. On wildfire, the proposal uses fuels management as a justification for rescission. The agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." That sentence belongs to the agency, not to opponents of the proposal. The La Madre - Prospect area, 278 acres in the Humboldt-Toiyabe, and Mt. Charleston, where Charleston - Macks Cyn covers 11,378 acres, are forested refuges in the Nevada heat. They are already under pressure from visitation. Adding roads increases ignition risk by the agency's own measure. The agency must explain in the record why it departs from its own prior findings on fire occurrence. It is one thing to open a managed area to the public, but these are wild lands. Without protection, environments suffer from people who are not educated in outdoor recreation. The Currant - Duckwater B and Currant - East Slope areas have been family camping spots for decades, and implementing roads would cause them to lose their wildness. Enjoying nature has been passed through my family for generations. Being able to share these places with my children is important to me, and just like many other traditions, it deserves to be preserved. Sincerely, Alexis Shaul Las Vegas, Nevada