Comment Analysis · Docket FS-2025-0001

FS-2025-0001-601766

Opposes rescissionA1 strongSubstance 16/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment places on the record specific deficiencies in the EIS regarding habitat fragmentation for listed species in named roadless areas, quantified wildfire ignition data from DEIS Table 21, and the need to analyze cumulative effects with the Travel Management Rule amendment, while requesting an alternative that retains 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, 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

Wildlife Habitat
- “increased habitat fragmentation, loss of habitat connectivity”
- “road-related mortality in a number of federally-listed species”
- “evaluate impacts of the Roadless Rule rescission to big game populations”
- “evaluate impacts... on species of conservation concern”
Forest Management Wildfire
- “wildfire ignitions are closely associated with roads and road access”
- “human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System lands”
- “road access could increase the number and frequency of wildfires”
- “quantify the expected increase in human-caused ignitions from new road access”
Environmental Protection Biodiversity
- “address effects of the Roadless Rule rescission on the potential spread of invasive species”
- “linked roads and road construction to increased cover and spread of invasive plants”
- “evaluate impacts... to federally-listed plant species, such as whitebark pine”
- “analyze in the DEIS an alternative that retains the 2001 Roadless Rule's protections”

What it names

Roadless areas: Black MountainDinkey LakesGreenhorn CreekKings RiverSan Joaquin
Law cited: 36 CFR 212

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 To whom it may concern: I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule. I raise the following issues for the record and ask that the agency respond to each of them. Issue 1: Rescission of the Roadless Area Conservation Rule (hereafter “Roadless Rule rescission”) will result in increased habitat fragmentation, loss of habitat connectivity, and increased road-related mortality in a number of federally-listed species, including the Southern Sierra Nevada distinct population segment of fisher (Pekania pennanti), Bi-State distinct population segment of greater sage-grouse (Centrocercus urophasianus), and Sierra Nevada bighorn sheep (Ovis canadensis sierrae). Conservation assessments and strategies for these species have identified roads as significant sources of mortality and habitat fragmentation in these species. These significant impacts should be analyzed and addressed in the EIS, including in specific areas of concern – such as the Boundary Peak roadless area (Bi-state sage-grouse); Kings River, Dinkey Lakes, Black Mountain, and Greenhorn Creek roadless areas (Southern Sierra fisher); and San Joaquin and Hoover roadless areas (Sierra Nevada bighorn sheep). Additionally, I ask the agency evaluate impacts of the Roadless Rule rescission to big game populations, such as elk, mule deer, pronghorn, and moose. These impacts should be assessed to evaluate effects to habitat connectivity and population-level impacts in these species and how it may affect hunting and wildlife viewing activities by the public. Additionally, I ask that the agency evaluate impacts of the Roadless Rule rescission to federally-listed plant species, such as whitebark pine (Pinus albicaulis). Lastly, I ask the agency to evaluate the impacts of the Roadless Rule rescission on species of conservation concern identified in revised Land Management Plans on national forests. Issue 2: I ask that the Roadless Rule rescission EIS evaluate cumulative effects of the proposed action with other recent agency-wide policy changes proposed by the U.S. Forest Service. In particular, these cumulative effects should include the proposed amendment to the existing Travel Management Rule (36 CFR 212) announced on August 21, 2026 on the agency’s website. It should also include cumulative effects of any other recent policy changes that broadly affect National Forest System roads, such as Land Management Plan revisions and amendments. Issue 3: The U.S. Forest Service’s own fire data shows that wildfire ignitions are closely associated with roads and road access. Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System lands against 3.0 fires per million acres inside the affected roadless areas (DEIS Table 21, 2014-2024). The DEIS states that human-caused ignitions have increased in abundance with proximity to roads. The effects analysis itself concedes that road access could increase the number and frequency of wildfires. I ask that the agency quantify the expected increase in human-caused ignitions from new road access and weigh it against the claimed reduction in wildfire hazard. I also ask the agency to conduct a thorough evaluation of the effects of roads on wildfire ignitions on national forests and other federal lands using he best available science information. Issue 4: I ask that the agency please address effects of the Roadless Rule rescission on the potential spread of invasive species, such as cheatgrass, on National Forest System lands. Numerous scientific publications have linked roads and road construction to increased cover and spread of invasive plants and their potential to increase the frequency and rate of spread of wildfires in wildlands. I request that the agency respond in the record to each of the issues raised in my comment and that it analyze in the DEIS an alternative that retains the 2001 Roadless Rule's protections. Where this proposal rests on factual conclusions that differ from the agency's own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record. Sincerely, Susan Roberts Mammoth Lakes, California