Opposes rescissionA0 noneSubstance 6/24Posted October 6, 2026 On Regulations.gov
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 eliminatedThe agency says it considered and eliminated the alternative the comment proposes, with a reason. Cannot be defeated from the comment text alone.
Already addressedThe 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 decisionThe agency says the point belongs to a later, site-specific decision. Cannot be defeated from the comment text alone.
Misreads the proposalThe agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
Not requiredThe agency says the analysis the comment asks for is not required. Cannot be defeated from the comment text alone.
Preference notedThe 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 shownThe agency says the comment asserts a harm without showing how the action causes it. Defeated when the comment shows the mechanism.
Outside the scopeThe agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.
Certified not substantiveThe agency certifies the comment raises nothing substantive. Defeated when the comment alleges illegality, which is substantive by the definition the certification runs on.
“deferred maintenance backlog of $6-$12 billion usd”
“taxpayers, and the USFS clearly cannot shoulder the burden of new road construction and maintenance”
“not further burden our agencies and taxpayers with backlog and debt”
What it names
Roadless areas
Caples Creek
Works cited
Furniss et al. 1991
The comment
I, Alejandro Cota strongly oppose options 2 and 3 proposed in regards to fully or partially rescinding the roadless rule.
As a resident of El Dorado County, California, I have a common cultural background with many Americans based on our recreational activities in the wonderful wildernesses of this country, like many, I depend on the resources safeguarded by the roadless rule.
In El Dorado County and many other counties countrywide people are dependent on both in-stream reservoirs and groundwater aquifers for reliable clean water for drinking, agriculture, and household and municipal use, and wildlife and the human lifestyles and industries dependant on wildlife. Our upland roadless areas are key hydrological landscapes and road building would have significant destructive and pollutive consequences by breaking the subsurface flow of water through the topsoil, which filters and sinks precipitation into aquifers as well as streams, and also holding up to 27,000gallons/acre/1%organic matter.
With roads cutting across places in my own region like Pyramid IRA, North Fork American IRA, Mt Rose IRA, Dardanelles IRA, and Caples Creek IRA, we would see massive channelization of precipitation, especially as we are tending to see the snow line climb and more moisture falling as rain instead of snow than we used to, which would rip apart these steep, gravelly, wildernesses, sending cascades of sediment down through the entire watershed, potentially decimating keystone fish populations and endangered and endemic species treasured across the west.
This would also burden our reservoirs, causing reduced holding volume and lifespan if not catastrophic failure to some aging infrastructure.
As we’ve just seen in Texas where border wall construction has disrupted the delicate hydrology, leading to both structural undermining and complete burying of the wall by channelized water, when a place with inherently erosion prone soils, intense rainfall patterns, and slopes has roads carved into it, destruction erosion is inevitable.
With a deferred maintenance backlog of $6-$12 billion usd, the taxpayers, and the USFS clearly cannot shoulder the burden of new road construction and maintenance in the most remote and erosion prone locations in the country.
Additionally, we in El Dorado County and elsewhere cannot afford to increase our risk of wildfire, which according to 32 years of wildfire data, is likely to happen with any new road development in roadless areas, I quote,” Although proponents of rolling back the Roadless Rule claim it is needed for wildfire management, the peer-reviewed science shows the opposite. A 2026 study in Fire Ecology by Aplet, Hartger & Dietz analyzed 32 years of wildfire data across all eight contiguous-U.S. Forest Service regions and found wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads, compared to just 1.97 fires per 1,000 hectares in inventoried roadless areas—a fourfold difference. A separate national analysis (Balch et al., PNAS 2017) found that 84% of all U.S. wildfires are human-caused. Roads are the primary vector for human ignitions, so building roads into roadless areas is likely to result in more fires, not fewer.”
Endemic and endangered wildlife as well as common and iconic wild game species, all benefit from or even depend on roadless areas for survival and reproduction, and the industries and subcultures who depend on them eat or starve depending on the health of those wildlife populations.
Our culture in America, and particularly the west, has been a pioneering one, at first in charging headlong into the wilderness to tame it, and then in conservation of it before it, changing the world with the administrative decision to protect wildernesses for their own sake and for public enjoyment throughout the generations.
These roadless places are our most cherished landscapes, even held sacred by many, and even if they weren’t so valuable to they outdoorsman and the artist, we would still have a responsibility to preserve them to protect our water, dams, wildlife, and forests from fire, and not further burden our agencies and taxpayers with backlog and debt.
I strongly encourage solution 1, the no-action alternative to be adopted by the US Forest Service in consideration of the roadless rule.
Sincerely,
A.Cota