Comment Analysis · Docket FS-2025-0001

FS-2025-0001-556465

Opposes rescissionA2 moderateSubstance 9/24Owed an answerPosted October 5, 2026 On Regulations.gov

In short: The comment documents that the DEIS acknowledges increased wildfire risk, sedimentation, and water temperature changes in specific California national forests (Klamath, Siskiyou, Six Rivers, El Dorado) due to road access, while simultaneously eliminating conservation alternatives based on deregulatory mandates rather than forest health or fire mitigation.

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.

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
- “headwaters for major rivers”
- “water in your drainage starts up there”
- “sediment and vegetation removal... harm threatened fish populations”
- “raising water temperatures”
Wildlife Habitat
- “maintain scarce wildlife habitat for threatened and endangered species”
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
- “grizzly... have suffered habitat loss and the extirpation or fragmentation of their populations”
- “unfragmented forest... is really important”
Recreation Tourism Public Use
- “quiet, remote and self-reliant recreation”
- “21,808 miles of trails inside the affected areas”
- “I enjoy hiking in these areas”
- “lost recreation benefit”
Economic Impact Fiscal
- “Roads are also more expensive to maintain than we can afford”
- “net present value that runs to negative $92 million”
- “Maximum projected timber revenue is $5.2 to 11.4 million a year”
- “road mileage, deferred maintenance and management costs are likely to increase”

What it names

National Forests: Klamath National Forest Six Rivers National Forest
Roadless areas: San Jose
Works cited: Carter 2005Haddad et al. 2015Patric 1976Swift 1988

The comment

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

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I live in San Jose, California. Public lands matter to me because they allow spaces that people, me included can connect to nature. In these public lands you can see what is left of these ecosystems in action and get a better understanding of how the world around us is supposed to work. Some areas near me that will be affected are the Klamath National Forest, the Siskiyou National Forest, the Six Rivers National Forest and the El Dorado National Forest. These areas hold headwaters for major rivers that sustain wildlife, snowpact and maintain scarce wildlife habitat for threatened and endangered species. I enjoy hiking in these areas as well. In these areas, there are 21,808 miles of trails inside the affected areas, including 1,127 miles of national scenic and historic trails, and most of those miles are non-motorized. The DEIS concedes the no-action alternative maintains the most opportunities for quiet, remote and self-reliant recreation, and that under rescission the settings could shift toward more developed conditions. You do not have to camp inside a roadless area to be affected: the water in your drainage starts up there, and the wildlife you hope to see moves through (DEIS recreation analysis). As I am also a fisherman, an unfragmented forest or any endangered habitat for that matter is really important for rivers and their water quality. The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent, and its own words on wide-ranging mammals like the grizzly: they “have suffered habitat loss and the extirpation or fragmentation of their populations.” (DEIS wildlife analysis; Haddad et al. 2015). Another thing is that I want the forests managed responsibly, only around 6% of the untouched old growth forest remains in the US. The purpose and need is to reduce regulatory burden and return decisionmaking to local officials, not forest health and not fire. Every conservation alternative was eliminated for failing that purpose: more acreage “would not be responsive to the deregulatory executive orders,” and one option was cut partly because analysing roadless values is “an administrative and legal burden for the agency.” The agency even monetized what roadlessness itself is worth to people who never visit: $5.3 to $11.5 million a year forgone, landing in the same range as the timber gain, which is why its own accounting cannot clear zero. And in its own words, “This proposed rescission does not mandate timber cutting or road construction”: nothing about management is promised, only the removal of the protection (DEIS purpose and need; alternatives analysis). Roads also cause fires. The agency’s own new analysis, 2014 to 2024: human-caused ignitions run 22.4 per million acres per year on roaded national forest land, against 3.0 inside the affected roadless areas. Seven and a half times. Its own conclusion: “human caused ignitions increase in abundance with proximity to roads,” and its effects analysis concedes road access could increase the number and frequency of wildfires (DEIS Table 21). Roads are also more expensive to maintain than we can afford, as this is taxpayer money. Road appropriations fell from $234 million in 2004 to $73 million in 2024, against a $6.9 billion deferred maintenance backlog. The supplemental funding is expiring. Maximum projected timber revenue is $5.2 to 11.4 million a year, against up to $6.1 million a year in lost recreation benefit by its own figures, and the agency’s own cost-benefit analysis states a net present value that runs to negative $92 million. The DEIS states outright that road mileage, deferred maintenance and management costs are likely to increase (DEIS economics and infrastructure analysis; USDA Cost Benefit Analysis, p. 29). Sediment and vegitation removal near or within proximity of these headwaters due to these roads in these areas harm threatened fish populations by killing eggs and raising water temperatures. The DEIS: sedimentation from harvest can promote excessive substrate movement and negatively impact fish such as bull trout by causing egg and juvenile mortality and reduced suitable habitat. Roads and their skid trails and landings contribute up to 90 percent of the sediment from a timber sale (DEIS; USFWS 2024; Patric 1976; Swift 1988). The DEIS: removing riparian vegetation can raise stream temperatures beyond what suits cold-water species, and warmer temperatures can reduce egg survival, rearing densities and growth of coho salmon. The affected area includes Essential Fish Habitat and critical habitats managed by NMFS (DEIS; Carter 2005). For the reasons stated above and many more, fully or partially rescinding the Roadless Rule under Alternatives 2 and 3 of the draft EIS would cause irreversible harm and permanently negatively effect all peoples in the US.