Comment Analysis · Docket FS-2025-0001

FS-2025-0001-406439

Opposes rescissionA3 weakSubstance 11/24Owed an answerPosted September 15, 2026 On Regulations.gov

In short: The comment establishes that the DEIS fails to provide the required watershed-level analysis for the North Mountain IRA in the Stanislaus National Forest, specifically regarding sediment pollution and stream temperature impacts on the Tuolumne River headwaters, and cites scientific data demonstrating the specific hydrological risks of road construction in that location.

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

A3 weak: Substantive, but easier to set aside.

Owed an answer on Analytical gap, Evidence.

Standard dismissals it defeats

Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
Outside the scope The agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.

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.
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.
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

Water Quality Quantity
- “water supply comes from the Hetch Hetchy Reservoir”
- “repeal of the roadless rule jeopardizes the preservation of the Tuolumne River”
- “Forest roads are the single largest anthropogenic source of non-point sediment pollution”
- “maintaining clean drinking water for communities across the country”
Environmental Protection Biodiversity
- “remove riparian canopy at every stream crossing”
- “For cold-water aquatic species, temperature increases of even 1–2°C alter dissolved oxygen concentrations”
- “exposing channels to direct solar radiation”
- “altering water sediment transport processes within watersheds”
Governance Policy Process
- “The DEIS must provide watershed-level analysis specific to the North Mountain IRA”
- “not programmatic generalizations applied across all inventoried roadless areas”
- “the analysis must reflect that specificity”

What it names

National Forests: Stanislaus National Forest
Roadless areas: North MountainTuolumne River

The comment

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

Dear Chief Schultz: As someone who lives in an area whose water supply comes from the Hetch Hetchy Reservoir, the motion to rescind the Roadless Area Conservation rule is of great concern to me. The Tuolumne River, which provides almost 100% of the Hetch Hetchy Reservoir's water, runs directly through public land that is currently protected by the roadless rule. Water is life. The survival of our Bay Area communities quite literally depends on the downstream flow of water from the Tuolumne River, and repeal of the roadless rule jeopardizes the preservation of the Tuolumne River in a big way. Regarding the North Mountain in the Stanislaus National Forest, California: Forest roads are the single largest anthropogenic source of non-point sediment pollution in national forests. The North Mountain IRA, Stanislaus National Forest, currently contributes zero road-generated sediment to its streams. Every road mile constructed in this watershed introduces impervious surfaces, exposed soil, and direct sediment delivery points that did not previously exist. Roads built in the North Mountain IRA, Stanislaus National Forest, would remove riparian canopy at every stream crossing, exposing channels to direct solar radiation. Stream temperatures rise measurably at these points. For cold-water aquatic species, temperature increases of even 1–2°C alter dissolved oxygen concentrations, metabolic rates, and competitive dynamics. The effect is cumulative across multiple crossings within a watershed. The DEIS must provide watershed-level analysis specific to the North Mountain IRA, Stanislaus National Forest — not programmatic generalizations applied across all inventoried roadless areas. The geology, soils, slopes, precipitation, stream network, and downstream uses of this watershed are specific to this place, and the analysis must reflect that specificity. "Compacted forest roads exhibit significantly higher average runoff coefficients (65%) than undisturbed forested areas (7%). This leads to extreme soil erosion rates ranging from 20 to 500 tons per hectare per year in the short term, markedly surpassing the rates observed in undisturbed mountainous forested watersheds (approximately 1 to 5 tons per hectare per year). Forest roads serve as conduits for the transport of runoff and sediment, fundamentally altering water sediment transport processes within watersheds by intensifying channelized flow and enhancing sediment transport efficiency." — MDPI Forests (open access journal review article), 2024 The U.S. National Forests are the headwaters of our great rivers and the largest source of municipal water supply in the nation. According to DellaSala (2011), national forests supply drinking water to at least 124 million people in more than 3,400 communities across 33 states—roughly a third of all national-forest runoff originates in inventoried roadless areas. Roads are a major cause of water pollution: erosion rates from logging roads have been documented as much as 850% higher than from undisturbed forest. Because the 2001 Roadless Rule protects these headwaters, including the headwaters of the Tuolumne River, it is vital for maintaining clean drinking water for communities across the country. With best wishes, Emeline