Comment Analysis · Docket FS-2025-0001

FS-2025-0001-545225

Opposes rescissionA3 weakSubstance 10/24Owed an answerPosted October 4, 2026 On Regulations.gov

In short: The comment documents specific local knowledge of roadless areas in the Eastern Sierra (Bridgeport, Lee Vining, Mammoth, Bishop, Big Pine, Lone Pine) and cites Pacific Biodiversity Institute data stating that 96.2% of fires start within 800 meters of a road to argue that rescinding the Roadless Rule would increase wildfire risk and environmental degradation.

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

A3 weak: Substantive, but easier to set aside.

Owed an answer on 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.
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.
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.
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

Environmental Protection Biodiversity
- “loss of biodiversity”
- “More invasive species in untouched areas”
- “sensitive/endangered/threatened species”
- “Devastating environmental consequences”
Forest Management Wildfire
- “96.2% of fires start within 800 meters of a road”
- “More roads mean more fires”
- “poorly managed matchstick forests that burn like gas”
- “Effective fire management should prioritize strategic, science-based, site-specific treatments”
Water Quality Quantity
- “clean water”
- “increase flooding and water loss through evaporation”
- “more water use”
Recreation Tourism Public Use
- “public lands user, recreationist”
- “solitude and landscape connectivity”
- “recreation access”

What it names

Roadless areas: Aurora CraterCoyote NorthGlass MountainIndependence CreekLaurel McgeeLog Cabin SaddlebagMono CratersMt. HicksRock CreekSan JoaquinSoldier CanyonTioga LakeWheeler Ridge

The comment

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

"I am writing as a public lands user, recreationist, Tribal member, scientist, Biologist, Horticulturist, Invasive Species and Forestry Expert to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (Roadless Rule). As a community member, recreator, business owner, Pissed Off Citizen, 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. Devestating environmental consequences if this rule is rescinded. More invasive species in untouched areas. More roads means more people ergo more pollution means increased animal death from accidents or trigger happy rednecks. Roads mean development, that means gas stations and hotels and more water use, more pesticides, loss of biodiversity and on and on. I cannot express my anger and frustration with these facist capitalist cowards that want to see the earth and everything that calls it home destroyed if it means profit, and perpetuation of some bullshit evil white christian nationalist agenda. These people are evil cowards sent to do nothing but destroy and tear down everything decent and positive. 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 Tribal member, community member, recreator, business owner, 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. More roads will increase logging of our old growth which will means poorly managed matchstick forests that burn like gas. More logging means hotter temperatures from loss of shade. This will also increase flooding and water loss through evaporation. The ignorant scum to reverse this no nothing about it and they dont care to. All they see is the potential profit and none of the harm they are causing. 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 Bridgeport (Mt. Hicks, Aurora Crater, Mt. Jackson, Hoover Areas etc.), Lee Vining (Mono Craters, Log Cabin Saddlebag, Tioga Lake etc.), 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). SAVE THE ROADLESS RULE!!!!!!!!!!!!!!!!!!!!!!! FUCK MIKE LEE FUCK DONALD TRUMP FUCK JD VANCE FUCK MAGA. LOVE EARTH. Keep the roadless rule by choosing the no action alternative."