Comment Analysis · Docket FS-2025-0001

FS-2025-0001-524048

Opposes rescissionA0 noneSubstance 7/24Posted September 30, 2026 On Regulations.gov

In short: The comment establishes the commenter's standing as a public lands user and recreator with intimate knowledge of specific roadless areas in the Mammoth and Bishop regions, and documents opposition to the rescission of the Roadless Rule based on concerns about local planning failures, wildfire risk from road expansion, and the protection of wildlife habitat and water quality.

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

Wildlife Habitat
- “wildlife habitat and connectivity”
- “sensitive/endangered/threatened species”
- “corridors for wildlife to maintain biodiverse”
- “habitat to many species of birds and animals”
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”
- “primary vector for fires is human ignition”
Water Quality Quantity
- “clean water”
- “They protect our water”
- “dirty the last clean streams”
- “water and trees we need for CO2 absorption”
Recreation Tourism Public Use
- “renewing a sense of inner peace”
- “communing with wild nature”
- “solitude and landscape connectivity”
- “free in their own country from the noise”

What it names

Roadless areas: Coyote NorthGlass MountainLaurel McgeeRock CreekSan JoaquinWheeler Ridge

The comment

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

"I am writing as a public lands user 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. Roadless areas protect fragmented wildlife, water and trees we need for CO2 absorption. 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, clean water, soil erosion, 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. ) roadless area(s). I am particularly concerned about The claim that putting more roads in roadless areas will assist in accessing forest fires is a specious argument when the primary vector for fires is human ignition and the majority of fires started by humans happen on the sides of roads. Roadless areas are special for renewing a sense of inner peace and communing with wild nature. They offer habitat to many species of birds and animals. They protect our water. They offer corridors for wildlife to maintain biodiverse and not become genetically fragmented. As Wallace Stegner, the preeminent American writer wrote, ""Something will have gone out of use as a people if we ever let the remaining wilderness be destroyed; if we permit the last virgin forests to be turned into comic books and plastic cigarette cases; if we drive the few remaining members of the wild species into zoos or to extinction; if we pollute the last clear air and dirty the last clean streams and push our paved roads through the last of the silence, so that never again will Americans be free in their own country from the noise, the exhausts, the stinks of human and automotive waste."". Keep the roadless rule by choosing the no action alternative."