Comment Analysis · Docket FS-2025-0001

FS-2025-0001-413849

Opposes rescissionA0 noneSubstance 7/24Posted September 15, 2026 On Regulations.gov

In short: The comment establishes that the proposed rescission of the 2001 Roadless Rule would negatively impact specific California national forests (Angeles, Los Padres, Shasta-Trinity, Modoc) by increasing wildfire ignition risk, degrading recreation access, and violating tribal consultation requirements.

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
- “Hiking is one of my greatest joys”
- “quiet, undeveloped, and largely untouched by industrial activity”
- “loss of irreplaceable hiking and recreation land”
Wildlife Habitat
- “provide habitat for 57% of the country's vulnerable terrestrial species”
- “protected roadless land includes ponderosa pine forests”
- “habitat fragmentation”
Forest Management Wildfire
- “highest wildfire-ignition density occurs in lands within 50 meters of roads”
- “fewer than 1% of wildfires... started in roadless areas”
- “increased wildfire ignition risk from new roads”
Water Quality Quantity
- “protect drinking water supplies”
- “watersheds near the Lake Tahoe Basin”
- “threats to clean water”
Tribal Sovereignty
- “Majority of Tribal governments consulted have opposed the rescission”
- “threat to inherent rights, tribal sovereignty”
- “inadequate Tribal consultation”

What it names

Roadless areas: Ponderosa Pine

The comment

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

To the U.S. Forest Service, I am writing as a California resident to strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule, which would strip protections from nearly 45 million acres of National Forest System land nationwide — including roughly 4 million acres across California's 21 national forests, from the Angeles and Los Padres in the south to the Shasta-Trinity and Modoc in the north. I urge the agency to withdraw this proposal. This issue is personal to me. Hiking is one of my greatest joys, and California's roadless national forest land is exactly the kind of place I go to experience it — quiet, undeveloped, and largely untouched by industrial activity. Opening these areas to road-building and logging would permanently change the character of trails and wild landscapes that I and countless other Californians rely on for recreation. Once roads and logging infrastructure move into these areas, that sense of remoteness is gone for good. Beyond my own interest in hiking, the ecological stakes are significant. Roadless areas make up just 2% of land in the lower 48 states yet provide habitat for 57% of the country's vulnerable terrestrial species. In California specifically, protected roadless land includes ponderosa pine forests in the Modoc, giant sequoia groves, and undeveloped stretches of the central Sierra Nevada near Yosemite. The agency's stated rationale — that repeal is necessary to reduce wildfire risk — is not well supported by the evidence. Research has found that the highest wildfire-ignition density occurs in lands within 50 meters of roads, and fewer than 1% of wildfires in the lower 48 states since 2010 started in roadless areas of national forests. More roads generally mean more human activity and more opportunities for human-caused ignitions, not fewer. These forests also protect drinking water supplies that Californians depend on, including watersheds near the Lake Tahoe Basin, and they support the hunting, fishing, and outdoor recreation economies of rural communities throughout the state. Finally, I have serious concerns about the process behind this proposal. The majority of Tribal governments consulted have opposed the rescission, viewing it as a threat to inherent rights, tribal sovereignty, cultural survival, and the ecological health of ancestral homelands. A decision of this magnitude should not move forward without genuine, good-faith consultation and consent from the Tribes whose lands and rights are most directly affected. For these reasons — the loss of irreplaceable hiking and recreation land, habitat fragmentation, increased wildfire ignition risk from new roads, threats to clean water, and inadequate Tribal consultation — I ask that the Forest Service withdraw the proposed rescission and retain the 2001 Roadless Rule in full for California's national forests and nationwide. Sincerely, Carrissa Rogers