Comment Analysis · Docket FS-2025-0001

FS-2025-0001-595375

Opposes rescissionA1 strongSubstance 18/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment establishes that the Draft EIS fails to analyze the impacts of post-harvest herbicide use on municipal source watersheds, relies on data that contradicts its wildfire rationale, ignores a $6.9 billion maintenance backlog and funding expirations, and defers site-specific analysis of timber harvest impacts on old-growth forests and ESA-listed species, thereby supporting the retention of the 2001 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

A1 strong: Must be answered — it names the law.

Owed an answer on Analytical gap, Evidence, Alternative, Legal.

Standard dismissals it defeats

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.
Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
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.

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.
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.
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.

Topics

Water Quality Quantity
- “Drinking water. About 90 percent of my tap water comes from EBMUD's Mokelumne River watershed”
- “Alternative 1 "provides the greatest protection of water quality"”
- “road construction is "the largest source of sediment related to timber harvest operations"”
- “protections should be retained in municipal source watersheds”
Forest Management Wildfire
- “The DEIS's own data undercut its fire rationale”
- “human-caused ignitions are over seven times higher”
- “Fuel reduction near communities is already permitted under the 2001 Rule”
- “commercial timber harvest and new road construction in source watersheds are not necessary to achieve it”
Environmental Protection Biodiversity
- “Roadless areas protect some of the last undisturbed forest, cold headwater streams and wildlife corridors”
- “may affect, and is likely to adversely affect 327 ESA-listed species and 71 critical habitats”
- “11-16% of the operable area where plans allow harvest is old growth”
- “retain the 2001 Roadless Rule (Alternative 1)”
Economic Impact Fiscal
- “The DEIS reports a $6.9 billion deferred maintenance backlog for roads and bridges”
- “No prudent fiscal strategy adds new liabilities to a portfolio that cannot maintain the assets it already has”
- “timber revenue "would not be sufficient to cover the costs of constructing and maintaining all new roads"”
- “disclose the life-cycle cost of new roads, and how it would be paid”

What it names

National Forests: Stanislaus National Forest Stanislaus National Forest
Law cited: 36 CFR 294.13(b)

The comment

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

I oppose the proposed rescission of the Roadless Area Conservation Rule and support Alternative 1 (No Action). I live in Piedmont, California, and have a deep background in finance, including evaluating the costs, risks and returns of major investments. Measured that way, this proposal fails on its own record. Page citations are to the Draft EIS (DEIS). 1.Drinking water. About 90 percent of my tap water comes from EBMUD's Mokelumne River watershed, which EBMUD describes as "largely protected from human activity" and consisting "mostly of national forests and undeveloped lands" (EBMUD 2023 Annual Water Quality Report). That watershed includes inventoried roadless land on the Stanislaus National Forest along the North Fork Mokelumne River canyon. The DEIS finds that nearly 5 million people in the Pacific Southwest Region draw water from intakes in watersheds containing affected IRAs, more than any other region, and calls the region "particularly vulnerable" (Table 35, pp. 121-123). It acknowledges that these areas "typically have good water quality due to limited disturbance," that road construction is "the largest source of sediment related to timber harvest operations," and that Alternative 1 "provides the greatest protection of water quality" (p. 122). Post-fire and post-harvest reforestation in California increasingly relies on herbicides, including glyphosate; the Caldor Fire Reforestation Project, for example, lists glyphosate among five herbicides it may use (Lake Tahoe Basin). The DEIS mentions herbicides only for invasive-plant control, conceding they can have "unintended adverse effects" on terrestrial and aquatic species (p. 142), and never analyzes post-harvest herbicide use or its effects on source water. Fuel reduction near communities is already permitted under the 2001 Rule (36 CFR 294.13(b); DEIS Table 1, p. 14); commercial timber harvest and new road construction in source watersheds are not necessary to achieve it. At minimum, protections should be retained in municipal source watersheds. 2.Wildfire. The DEIS's own data undercut its fire rationale. Ignition density on other NFS lands is about four times that of affected IRAs (41.8 vs. 12.0 fires per million acres per year, Table 18, p. 87), and human-caused ignitions are over seven times higher (22.4 vs. 3.0, Table 21, p. 90). The DEIS concedes that "human caused ignitions increase in abundance with proximity to roads" (p. 90) and that IRAs burned a smaller share of their area (8.7% vs. 13.8%, Table 18). It also admits "a lack of roads has not prevented fire prevention or protection measures" (p. 105). Its answer to added ignitions, restricting public access to new roads (p. 105), depends on gates, closures and enforcement the agency cannot fund (see 3). 3.Fiscal responsibility. The DEIS reports a $6.9 billion deferred maintenance backlog for roads and bridges, counting passenger-car roads only, and a drop in annual road appropriations from $234 million (2004) to $73 million (2024); supplemental GAOA funding expired in 2025 and IIJA funding was set to expire September 30, 2026 (p. 43). It assumes timber revenue "would not be sufficient to cover the costs of constructing and maintaining all new roads related to a project" (p. 45). No prudent fiscal strategy adds new liabilities to a portfolio that cannot maintain the assets it already has. The agency should address the existing backlog and disclose the life-cycle cost of new roads, and how it would be paid, before removing protections. 4.Old growth and intact habitat. Roadless areas protect some of the last undisturbed forest, cold headwater streams and wildlife corridors. The DEIS finds the proposal "may affect, and is likely to adversely affect" 327 ESA-listed species and 71 critical habitats (pp. 25, 161), and that 11-16% of the operable area where plans allow harvest is old growth and 54-63% is mature forest (p. 78). It projects 253,000-557,000 ccf of added harvest per year (p. 77), yet defers site-specific analysis because future activities are "uncertain" (p. 32). The agency cannot model where the timber is while declining to analyze the harm in those same places. I urge the Forest Service to withdraw the proposed rescission and retain the 2001 Roadless Rule (Alternative 1). If any change proceeds, it should occur through state-specific rulemaking with full analysis of water supply, wildfire, fiscal and habitat impacts. Other sources: EBMUD 2023 Annual Water Quality Report (ebmud.com); CSERC, Stanislaus NF roadless areas (cserc.org); South Tahoe Now, Caldor Fire Reforestation Project (May 4, 2026); KUNR, Tahoe herbicide concerns (May 27, 2026); Mother Jones/Reveal investigation on Forest Service glyphosate use in California (Apr. 2026). Jeff East Bay, CA