Comment Analysis · Docket FS-2025-0001

FS-2025-0001-559223

Opposes rescissionA0 noneSubstance 8/24Posted October 5, 2026 On Regulations.gov

In short: The comment places on the record specific personal use of the Sierra, El Dorado, and Desolation Wilderness areas, along with cited scientific data demonstrating that inventoried roadless areas have significantly lower wildfire ignition densities than lands near roads, to support the request to maintain the Roadless Rule.

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

  • Water Quality Quantity
    • “protect watersheds to keep streams and the lakes they feed clean”
    • “In California these areas supply 50% of our drinking water”
  • Forest Management Wildfire
    • “protect our forests from fire as data on fire ecology has shown”
    • “highest wildfire-ignition density was in lands within 50 m of roads”
    • “90% of wildfires in the US happen with half mile of a road”
  • Environmental Protection Biodiversity
    • “protect our wilderness and national forests”
    • “I value the diversity of the Jeffrey, Lodgepole, Sugar pines, and the fir trees and the fauna they support”
    • “clean, untouched forests and meadows”
  • Recreation Tourism Public Use
    • “hiked and horsepacked the Dinkey Creek Lakes backcountry”
    • “hiked sections at risk on the Tahoe Rim trail”
    • “hikes and telemark skis the backcountry there”

What it names

National Forests
Sierra National Forest
Works cited
10.1186/s42408-026-00450-2

The comment

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

I am a mom and a 3rd generation Californian. I oppose the elimination of the Roadless Rule. I support Alternative 1: No Action Inventoried Roadless Areas protect watersheds to keep streams and the lakes they feed clean. In California these areas supply 50% of our drinking water. Inventoried Roadless Areas protect our forests from fire as data on fire ecology has shown. From a meta study published 29 January 2026, "Inventoried Roadless Areas had (1.97 fires/1000 ha). The highest wildfire-ignition density was in lands within 50 m of roads (7.99 fires/1000 ha).” That is 4 X the fires near roads! This study reviewed dozens of previously published and peer-reviewed studies from 1992 to 2024. Aplet, G.H., Hartger, P. & Dietz, M.S. Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. fire ecol 22, 8 (2026). https://doi.org/10.1186/s42408-026-00450-2 Inventoried Roadless Areas protect our wilderness and national forests because they are adjacent and surround these protected forests. Another 2007 study by Peter Morrison found 90% of wildfires in the US happen with half mile of a road. Morrison, P.H. 2007. Roads and Wildfires. Pacific Biodiversity Institute, Winthrop, Washington. 40 p. I have a personal connection to many of these areas. Specifically I have hiked and horsepacked the Dinkey Creek Lakes backcountry in the Sierra National Forest. I have hiked sections at risk on the Tahoe Rim trail near Loon Lake in the El Dorado National Forest. My husband and two children spent a lot of time in the surrounds of the Desolation Wilderness area. My brother lives near the Glass Mountains and hikes and telemark skis the backcountry there. I have wonderful memories of these clean, untouched forests and meadows and it would break my heart to see them disturbed. I value the diversity of the Jeffrey, Lodgepole, Sugar pines, and the fir trees and the fauna they support. These wild areas are a national treasure. Please also note that the current rule already allows for forest management, clearing fuel loads and removing vegetation and putting in emergency roads if necessary. We do not need more roads through our forests. Please do NOT rescind the Roadless Rule. Thank you.

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