Comment Analysis · Docket FS-2025-0001

FS-2025-0001-496866

Opposes rescissionA2 moderateSubstance 16/24Owed an answerPosted September 28, 2026 On Regulations.gov

In short: The comment documents specific deficiencies in the DEIS analysis regarding unquantified sediment delivery to municipal intakes, lack of bear mortality projections despite acknowledged risks, failure to reconcile wildfire ignition data with hazard justifications, and the exclusion of reliance interests and small entity impacts from the Cost Benefit Analysis, while requesting the withdrawal of Docket FS-2025-0001.

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

A2 moderate: Hard to dismiss — it shows cause and effect.

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.
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.

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.
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
- “severe degradation of streams due to logging”
- “sediment buildup from runoff”
- “project the expected sediment delivery to the municipal intakes”
- “compounding harm the analysis does not attempt to quantify”
Wildlife Habitat
- “Bear range through the Stanislaus and Humboldt-Toiyabe forests”
- “increased contact and conflict that come with open roads in bear habitat”
- “bear mortality, and habituation and food reward”
- “What does the agency expect to happen to bears in roadless areas that become roaded?”
Recreation Tourism Public Use
- “led backpacking groups into the Eagle, Dome, and Carson-Iceberg roadless areas”
- “volunteers come largely because there are no roads and no industrial operations there”
- “The appeal would be gone if roads were built into this area”
- “lost recreation benefit at a minimum of $6.1 million a year”
Forest Management Wildfire
- “human-caused ignition density at 22.4 fires per million acres per year on roaded National Forest land”
- “human-caused ignitions increase in abundance with proximity to roads”
- “road access could increase the number and frequency of wildfires”
- “projecting the net change in ignition risk”

What it names

National Forests: Stanislaus National Forest Tahoe National Forest
Roadless areas: Castle PeakEagle

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeAnalytical gapEvidenceRequest

I am asking this agency to withdraw Docket FS-2025-0001. Watching what roads and logging do to forests and upper watersheds, has given me a particular way of assess proposed changes to public land protections. I have seen severe degradation of streams due to logging such that fishing was not possible, or simply very unappealing because of the damage caused by heavy machinery, slash piles, and sediment buildup from runoff. I have led backpacking groups into the Eagle, Dome, and Carson-Iceberg roadless areas of the Stanislaus National Forest, and into Castle Peak in the Tahoe National Forest, because I believe these places are provide unique value. I organize trail crews, collaborate with local foresters, and last year our team reopened three miles of trail in the Carson-Iceberg area that had been lost to undergrowth and downed trees. I bring volunteers to a backcountry hut at the base of Castle Peak to prepare it for winter, and those volunteers come largely because there are no roads and no industrial operations there. The appeal would be gone if roads were built into this area. The streams I have watched over decades carry the clearest argument against this rescission. The DEIS itself states that skid roads, trails, and log landings are the main cause of soil erosion and "can contribute up to 90 percent of the sediment generated by timber sale activity." That figure appears in the document and yet nothing follows it: no projection of how much sediment would reach waterways. The agency's own data further states that sedimentation from harvest can negatively impact fish by causing egg and juvenile mortality and reduced suitable habitat. The Eagle roadless area, 16,116 acres in the Stanislaus, holds springs and seasonal creeks already trampled by cattle, with sediment already clouding waters downstream. Adding road-based timber harvest to a watershed already under that stress is a compounding harm the analysis does not attempt to quantify. I ask that the agency project the expected sediment delivery to the municipal intakes downstream of these areas before it finalizes any rule. Bear range through the Stanislaus and Humboldt-Toiyabe forests I have traveled for more than thirty years. The DEIS cites the likelihood of increased contact and conflict that come with open roads in bear habitat can ultimately end in bear mortality, and habituation and food reward all increase with the use of even secondary unpaved roads. The agency entered that finding into the record and then did not carry it forward into a projection of mortality under the proposed action. What does the agency expect to happen to bears in roadless areas that become roaded? The record needs an answer. After fire, these places team with new life. You can see the resilience of the forest first hand. After industrial logging, these places are silent and feel much less alive. The agency's own fire data records human-caused ignition density at 22.4 fires per million acres per year on roaded National Forest land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads. The analysis itself concedes that road access could increase the number and frequency of wildfires. No quantification of that expected increase appears alongside the claimed wildfire-hazard justification for the rescission. I ask that the agency reconcile those two positions by projecting the net change in ignition risk before it proceeds. The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. I have paid millions in federal taxes over a long career, largely without reservation, because I saw value in what agencies like the Forest Service do. The trail work, the backpacking groups, the volunteer hut preparation at Castle Peak: all of it rests on a reasonable expectation that these roadless areas and their neighbors will not be handed to extractive industry. I am expressing a reliance interest. The agency must weigh it. The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. The Stanislaus, Tahoe, Eldorado, and Humboldt-Toiyabe forests I visit support permit holders whose entire operation is tied to specific roadless terrain, not to the national average across which the flexibility analysis spreads its numbers. The agency should withdraw the certification and assess the impact on the individuals and small entities actually holding permits in these areas. These forests are central to what public land means. Americans own them and want them protected. I still believe government can work for its citizens, if it would just listen to them. Sincerely, Scott Mattoon Stockton, California