Comment Analysis · Docket FS-2025-0001

FS-2025-0001-544595

Opposes rescissionA2 moderateSubstance 14/24Owed an answerPosted October 4, 2026 On Regulations.gov

In short: The comment documents that the draft EIS acknowledges adverse impacts on 327 threatened and endangered species, water quality degradation from road construction, and increased wildfire risk from road density, while the commenter cites external data showing that 78% of human-caused fires start near roads and that roadless areas protect critical watersheds, thereby establishing a record of specific deficiencies in the agency's analysis of these impacts.

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

Wildlife Habitat
- “critical habitat for a multitude of species including California and Northern Spotted Owls, fisher, salmon”
- “adversely affect 327 threatened and endangered species and 71 designated critical habitats”
- “important habitat for native trout, salmon, and elk”
- “crucial areas for wide-ranging carnivores like wolverines”
Water Quality Quantity
- “Communities depend on our National Forests for clean, fresh drinking water”
- “Inventoried Roadless Areas (IRA) protect over 130,000 km of streams and rivers”
- “Road construction and native surface forest roads are the largest source of sediment related to timber harvest operations”
- “ensure that communities continue to have clean safe drinking water”
Forest Management Wildfire
- “Rescinding the Roadless Rule will increase the risk of wildfire”
- “78% of human-caused fires on National Forests start within ½ mile of a road”
- “Road density is linked to human-caused wildfires, and as the density of roads increases so does the probability, number, and frequency of wildfire ignitions”
- “the 2001 Roadless Rule allows for forest management activities, including timber harvest, to reduce the risk of uncharacteristic wildfire”
Recreation Tourism Public Use
- “Backpacking in California in remote roadless areas... were formative experiences”
- “thrilled by the roadless areas here including the Rubicon and the American River Roadless areas”
- “high demand hunting and fishing areas”
- “favored by anglers and hunters”

What it names

National Forests: Six Rivers National Forest
Works cited: 10.1186/s42408-026-00450-210.1371/journal.pwat.0000538

The comment

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

October 2, 2026 Dear Secretary Rollins, I strongly oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I am a biologist who has spent more than 20 years working in and on topics affecting forests and public lands throughout the country and especially in California where I currently live. I have been recreating – backpacking, hiking, camping, bird watching, etc. - in National Forests even longer. Backpacking in California in remote roadless areas in the Stanislaus Forest and Six Rivers National Forest when I was younger were formative experiences that guided my career. Now I am exploring the incredible diversity of California and I am thrilled by the roadless areas here including the Rubicon and the American River Roadless areas. Eliminating the roadless rule would remove protections for 45 million acres of the wildest and most intact public lands across our National Forests. There is nothing like these irreplaceable and unique places. Alternative 3 would still open the majority – 31.7 million acres – to road building, logging and other development. This would imperil drinking water, habitat, Tribal values, recreation, fire risk, and it would be economically very costly. And the draft EIS acknowledges many of these known issues (e.g. increased road construction and timber harvest are likely to “introduce and spread invasive plant species due to ground disturbance.”). Intact Roadless areas provide critical habitat for a multitude of species including California and Northern Spotted Owls, fisher, salmon, and hundreds more. However, the DEIS acknowledges that eliminating the Roadless Rule would “adversely affect” 327 threatened and endangered species and 71 designated critical habitats for these species. These Roadless areas also overlap with high demand hunting and fishing areas and provide important habitat for native trout, salmon, and elk, favored by anglers and hunters and are crucial areas for wide-ranging carnivores like wolverines. (https://www.sciencedirect.com/science/article/pii/S0006320726002624). How does the Forest Service plan to prevent further degradation of these habitats and populations and mitigate harm if the Roadless Rule protections are eliminated? Communities depend on our National Forests for clean, fresh drinking water and Roadless areas are a key to maintaining this quality, providing 25 million Americans with affordable, clean water. Inventoried Roadless Areas (IRA) protect over 130,000 km of streams and rivers, representing 2.5% of total river length, and serve as the primary protection mechanism for more than 100,000 km of rivers (1.9%) (https://journals.plos.org/water/article?id=10.1371/journal.pwat.0000538). According to the DEIS,“Potentially affected inventoried roadless areas typically have good water quality due to limited disturbance,” and “Road construction and native surface forest roads are the largest source of sediment related to timber harvest operations, and sediment delivered to surface waters is a major source of water quality degradation.” for providing clean water and flood protection. The the Agency protect critical watersheds and ensure that communities continue to have clean safe drinking water and aquatic species are protected? Rescinding the Roadless Rule will increase the risk of wildfire. 78% of human-caused fires on National Forests start within ½ mile of a road (https://data.fs.usda.gov/geodata/edw/datasets.php?xmlKeyword=National+USFS+Fire+Occurrence+Point). Fires are four times more likely to start near a road than in a roadless forest, and logging also increases fire hazard (https://link.springer.com/article/10.1186/s42408-026-00450-2). The DEIS even admits “Road density is linked to human-caused wildfires, and as the density of roads increases so does the probability, number, and frequency of wildfire ignitions.” It would be disingenuous to claim that rescission will allow for fire related management since the 2001 Roadless Rule allows for forest management activities, including timber harvest, to reduce the risk of uncharacteristic wildfire, as well as to restore habitat for sensitive fish and wildlife species. In fact, nearly 2 million acres of Inventoried Roadless Areas have had hazardous fuels treatments to reduce fire risk. Why does the Agency think it is a good idea to deliberately increase fire risk in the midst of a wildfire crisis and how would it propose mitigating the increased risk? Finally, it is remarkable to me that the Forest Service is proposing to build new roads when – as anyone who has been on a Forest Service road knows – it is barely (and often, not) maintaining the more than 386,000 miles of current roads to a safe standard. In fact there is already over $6.9 billion in deferred road maintenance. Poorly maintained roads threaten public safety .