Comment Analysis · Docket FS-2025-0001

FS-2025-0001-576980

Opposes rescissionA0 noneSubstance 7/24Posted October 6, 2026 On Regulations.gov

In short: The comment establishes the commenter's personal connection to the Duncan Canyon Roadless Area in Tahoe National Forest and requests the retention of the 2001 Roadless Area Conservation Rule by selecting the No Action Alternative, specifically questioning why existing rule exceptions are insufficient for wildfire and safety needs.

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

  • Recreation Tourism Public Use
    • “hiking and backpacking”
    • “priceless memories of being together in this beautiful natural area”
    • “maintaining the natural beauty of our lands”
  • Environmental Protection Biodiversity
    • “working as a wildlife and landscape photographer”
    • “continued protection of the federal government is essential”
    • “maintaining a national conservation baseline”
  • Governance Policy Process
    • “select the No Action Alternative”
    • “evaluated independently by experts, and without regard to politics”
    • “Why are the Roadless Rule's existing exceptions insufficient”

What it names

National Forests
Tahoe National Forest
Roadless areas
Duncan Canyon

The comment

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

I live in San Antonio, TX and am writing to urge the U.S. Department of Agriculture to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. My connection to National Forest lands includes hiking and backpacking and working as a wildlife and landscape photographer. Ever-expanding development has and continues to encroach on unprotected lands and the continued protection of the federal government is essential to maintaining the natural beauty of our lands. Duncan Creek is one place that has shaped my views on this proposal. It is within the Duncan Canyon Roadless Area Inventoried Roadless Area in Tahoe National Forest. I have taken two of my grandchildren to this area and we have had priceless memories of being together in this beautiful natural area. I believe maintaining a national conservation baseline matters. These lands should be protected with exceptions when needed, evaluated independently by experts, and without regard to politics. Before rescinding the national rule, I would like USDA to answer this question: Why are the Roadless Rule's existing exceptions insufficient to meet legitimate wildfire, public safety, and forest-management needs? For these reasons, I urge USDA to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. Thank you for considering my comments.

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