Comment Analysis · Docket FS-2025-0001

FS-2025-0001-513380

Opposes rescissionA0 noneSubstance 7/24Posted September 29, 2026 On Regulations.gov

Campaign — One letter sent by 10 or more people, copied or lightly reworded. One of 10 submissions in its group. See the letter, its submissions and topics.

In short: The comment establishes the commenter's standing as a recreationist with intimate knowledge of specific roadless areas in the Mammoth, Bishop, Big Pine, and Lone Pine districts, and documents opposition to the rescission of the 2001 Roadless Rule based on concerns regarding wildfire risk, wildlife habitat, and the inadequacy of local planning processes to protect these values.

Scored as the letter — The shared letter of a family, scored once for everyone who sent it.

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

Wildlife Habitat
- “concerned about wildlife habitat and connectivity”
- “killing species”
- “cumulative loss and fragmentation of roadless landscapes”
Forest Management Wildfire
- “96.2% of fires start within 800 meters of a road”
- “more roads mean more fires”
- “Effective fire management should prioritize strategic, science-based, site-specific treatments”
Recreation Tourism Public Use
- “recreation access”
- “reducing the recreation in wild spaces”
- “intimate knowledge of the Lee Vining... roadless area(s)”
Climate Carbon Storage
- “climate resilience”
- “maintain ecological... values”

What it names

Roadless areas: Coyote NorthGlass MountainIndependence CreekLaurel McgeeRock CreekSan JoaquinSoldier CanyonWheeler Ridge

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisEvidenceRequestAlternative

"I am writing as a recreationist to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (Roadless Rule). As a recreator, I am concerned about the claim that the proposed rescission emphasizes greater local decision-making authority in forest planning processes. The Roadless Rule was established in part due to the failure of local forest planning processes to maintain ecological, cultural, and public values of roadless areas to an adequate level across the National Forest System. Returning these decisions to wholly local planning processes should not be treated as a substitute for consistent nationwide protection measures. Once nationwide protections are removed, individual decisions may fail to account for the cumulative loss and fragmentation of roadless landscapes across the National Forest System. As a recreator, I am concerned about the claim that removing the Roadless Rule is necessary to reduce wildfire risk. 96.2% of fires start within 800 meters of a road (Pacific Biodiversity Institute). It is clear that more roads mean more fires. Wildfire risk reduction should not be used as a blanket justification for expanding roads and resource extraction into millions of acres of roadless wildlands. Effective fire management should prioritize strategic, science-based, site-specific treatments where they meaningfully protect communities and firefighters, rather than broadly removing protections from remote landscapes. I am particularly concerned about wildlife habitat and connectivity, sensitive/endangered/threatened species, invasive species, biodiversity, clean water, soil erosion, climate resilience, recreation access, firefighter risk, landscape fire restoration, solitude and landscape connectivity. The claim that putting these forests under local control would have little adverse impact on land managers' ability to protect undeveloped wildlands puts these values at risk. I have an intimate knowledge of the Mammoth (Laurel McGee, Sherwin, San Joaquin, Rock Creek, Glass Mountain etc.), Bishop (Wheeler Ridge, Buttermilk, Coyote North and South, Boundary Peak, etc. ), Big Pine and Lone Pine (Soldier Canyon, Paiute, Tinemaha, Independence Creek etc.) roadless area(s). Keep the roadless rule by choosing the no action alternative."