Comment Analysis · Docket FS-2025-0001

FS-2025-0001-584531

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 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

  • Environmental Protection Biodiversity
    • “protects multitudes of species and biodiversity”
    • “Supports large old growth forest, California spotted owl and other old growth dependent species”
    • “maintain ecological, cultural, and public values of roadless areas”
  • Forest Management Wildfire
    • “96.2% of fires start within 800 meters of a road”
    • “Wildfire risk reduction should not be used as a blanket justification for expanding roads”
    • “Effective fire management should prioritize strategic, science-based, site-specific treatments”
  • Water Quality Quantity
    • “protects the air and drinking water”
    • “Supports one of the few wild runs of threatened spring chinook salmon and winter steelhead”
    • “National Wild and Scenic River protection for Mill Creek”
  • Climate Carbon Storage
    • “I am particularly concerned about climate resilience”
    • “The Roadless Rule keeps old growth forests intact”
    • “critical infrastructure as the effects of climate change intensify”

What it names

National Forests
Lassen National Forest
Roadless areas
Mill Creek

The comment

"I am writing as a public lands user to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (Roadless Rule). As a community member, 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. Political partisanship and corruption is being factored into the current push to dismantle this rule, which is not reflective of the opinions of the people they represent. The Roadless rule is supported by the VAST majority of voters across the political spectrum— 76% according to recent Pew polling. 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 community member, 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. As a sister in-law of a CA firefighter. We’ve seen and have intimate knowledge of wildfires. They will tell you that the majority of fires are due to human activities. Roads invite more people and vehicles deeper into the woods. Those roads that are built “in case of wildfires” are also pushing potential fires deeper into the landscape. 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 climate resilience. 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 Lassen National Forest: Mill Creek Inventoried Roadless Area roadless area(s). I am particularly concerned about Climate resilience affects all of us. It affects all animals and plants, and that affects you. The Roadless Rule keeps old growth forests intact, protects multitudes of species and biodiversity, protects the air and drinking water, increases wildfire resilience, protects from land erosion, and is critical infrastructure as the effects of climate change intensify and create unstable and unpredictable changes to our everyday lives. All of these changes affect you, your loved ones, and all future generations of your family. This area - Supports large old growth forest, California spotted owl and other old growth dependent species. - Supports one of the few wild runs of threatened spring chinook salmon and winter steelhead flowing into the Central Valley. - Homeland of the Yahi Indians and the story of Ishi. - Important migration corridor for the Tehama black tailed deer herd - The Mill Creek Inventoried Roadless Area is recommended for wilderness protection by the USFS. - The USFS recommended wilderness protection for the Mill Creek Inventoried Roadless Area and National Wild and Scenic River protection for Mill Creek. Not only is the change proposed to the Roadless Rule terrible on it’s face for animals, the environment, and the people these biomes support in different ways (often unnoticed but absolutely crucial to our health), it’s also a cynical bid to disregard the will of the vast majority of The People in order to make a few people richer. It steals an asset that is explicitly under the stewardship of the People of the United States. Our tax dollars are what supports these areas. We do not consent to this change. And the corrupt few who are in power and pushing for this rule are not doing their job of representing the will of The People. Keep the roadless rule by choosing the no action alternative."

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