Comment Analysis · Docket FS-2025-0001

FS-2025-0001-590018

Supports rescissionA0 noneSubstance 4/24Posted 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

Public Land Access Rights
- “restrict public access”
- “motorized recreation hubs”
- “multiple-use access”
- “OHV destinations”
Governance Policy Process
- “regulatory confusion”
- “administrative burdens”
- “legally mandated federal process”
- “administrative rulemaking”
Forest Management Wildfire
- “critical firefighting”
- “emergency vehicle ingress/egress”
- “high-fire-risk regions”
- “routine route maintenance”

What it names

National Forests: Humboldt-Toiyabe National Forest Inyo National Forest

The comment

Subject: Public Comment on the Proposed Rescission of the 2001 Roadless Area Conservation Rule (RIN0596-AD66) To Whom It May Concern, I am writing to express my strong support for the rescission of the 2001 Roadless Area Conservation Rule, and to specifically advocate that all Inventoried Roadless Areas (IRAs) within the Inyo National Forest and the Humboldt-Toiyabe National Forest be fully excluded from this designation. The current framework relies on a fundamentally misleading premise and creates regulatory confusion by treating multi-use lands across the Sierra Nevada and Great Basin as pseudo-wilderness without proper legislative justification. First, the term "roadless" is factually inaccurate, and there is no better example of this than Coyote Valley / Coyote Flat in the Inyo National Forest. Coyote Valley is widely recognized as one of the most popular and highly utilized Off-Highway Vehicle (OHV) destinations in the entire Eastern Sierra. Despite being home to a robust network of well-established, heavily used 4x4 and OHV routes—including the critical Coyote Valley Road (FS 7S10)—large portions of this area are inappropriately designated as an IRA. Labeling premier motorized recreation hubs and active multi-use corridors across the Inyo and Humboldt-Toiyabe as "roadless" is a direct contradiction in terms and misleads the public about actual infrastructure on the ground. Second, this systemic mislabeling creates severe administrative burdens that unnecessarily restrict public access. By keeping vast tracts of land in the Inyo and Humboldt-Toiyabe forests under the IRA umbrella, the USFS is pressured to manage them with heavy-handed, restrictive policies that closely mimic formal Wilderness Area designations. This severely impacts local land management by complicating routine route maintenance, hindering critical firefighting and emergency vehicle ingress/egress in high-fire-risk regions, and placing undue burdens on historic permitted grazing operations and motorized recreation. If specific tracts of land within these national forests truly warrant the strict protections of a Wilderness Area, they must be proposed through the transparent, legally mandated federal process. The authority to designate permanent Wilderness belongs exclusively to Congress under the Wilderness Act, ensuring local economic input, resource balancing, and democratic accountability. Using administrative rulemaking to lock up active, motorized recreation areas and multi-use lands across the Inyo and Humboldt-Toiyabe under the guise of a "roadless" label is inappropriate, exclusionary, and factually flawed. These areas are not wilderness, and they do not deserve back-door special treatment that strips away multiple-use access. I urge the Department of Agriculture to finalize the rescission of the Roadless Rule and lift these designations across these critical western forests. Sincerely, Randy Short, President, Advocates for Access to Public Lands (AAPL)