Comment Analysis · Docket FS-2025-0001

FS-2025-0001-605599

Opposes rescissionA0 noneSubstance 7/24Posted October 7, 2026 On Regulations.gov

In short: The comment establishes that specific roadless areas in the Lee Vining, Mammoth, Bishop, Big Pine, and Lone Pine regions are at risk of fragmentation and increased wildfire ignition due to road expansion, citing data on fire proximity to roads and the commenter's professional experience as a wildland firefighter.

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

Forest Management Wildfire
- “96.2% of fires start within 800 meters of a road”
- “ignition density of 7.99 fires/1,000 ha within 50m of roads vs. 1.97 in inventoried roadless areas”
- “roads will be blocked by the heavy equipment that started them”
- “Effective fire management should prioritize strategic, science-based, site-specific treatments”
Water Quality Quantity
- “contribute to the natural filtration of drinking water”
- “affecting clean water sources”
- “drinking water that flows downstream to thousands of people”
Wildlife Habitat
- “eliminating wildlife habitat”
- “These areas hold so much value as wildlife habitats”
- “cumulative loss and fragmentation of roadless landscapes”
Recreation Tourism Public Use
- “wild sanctuaries that help people relief the stress of city life”
- “need wild places to escape to help reset our bodily systems”
- “humans need to disconnect to reconnect”

What it names

Roadless areas: Coyote NorthGlass MountainIndependence CreekLaurel McgeeLog Cabin SaddlebagMono CratersRock CreekSan JoaquinSoldier CanyonTioga LakeWheeler Ridge

The comment

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

"I am writing as a widland firefighter to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (Roadless Rule). As a wildland firefighter, 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 process to maintain ecological, cultural, and public values of roadless areas at an adequate level across the National system. Returning these decisions to wholly local planning processes should not be treated as a substitute for consistent nationwide protection measurements. 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. I would also like to emphasize that Overall, these zones are more safe without human interaction and need to remain wild. As a wildland firefighter, 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. 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 also want to emphasize that I firsthand deal with wildfires started by heavy equipment like the ones that would be utilized to construct the roads built in the wilderness. Furthermore, having access to these zones does not mean we will be better equipped to mitigate wildfires when they start because roads will be blocked by the heavy equipment that started them and that’s the reality. Additionally, more public lives will be at risk when they have access to these zones and fires start in these zones. Now it firefighters are committed to go and rescue said individuals who otherwise wouldn’t be there. I am particularly concerned about firefighter risk. The claim that putting these forests under local control would have little adverse impact on the land managers' ability to protect undeveloped wildlands puts these values at risk. I have an intimate knowledge of the Lee Vining (Mono Craters, Log Cabin Saddlebag, Tioga Lake etc.), Mammoth (Laurel McGee, Sherwin, San Joaquin, Rock Creek, Glass Mountain etc.), Bishop (Wheeler Ridge, Buttermilk, Coyote North and South, Boundary Peak, etc. ), Big Pine and Lone Pine (Soldier Canyon, Paiute, Tinemaha, Independence Creek etc.) roadless areas. I am particularly concerned about Aplet, Hartger & Dietz (2026) analyzed 32 years of contiguous-U.S. wildfire data and found ignition density of 7.99 fires/1,000 ha within 50m of roads vs. 1.97 in inventoried roadless areas These roadless areas are important to me because These areas hold so much value as wildlife habitats and contribute to the natural filtration of drinking water that flows downstream to thousands of people. Also, these zones provide wild sanctuaries that help people relief the stress of city life. We can’t forget we need wild places to escape to help reset our bodily systems. I also want to share this personal perspective: The areas described that would be potentially impacted by eliminating the Roadless Rule Act would not positively impact society as a whole. Let alone increasing wildfire danger by introducing more ignition sources, eliminating wildlife habitat and affecting clean water sources, it would eliminate wild places us as humans need to balance ourselves in this ever increasing busy and crowded world. It’s being forgotten that we as humans need to disconnect to reconnect from time to time. Let’s try and remember that by keeping it wild and roadless. Keep the roadless rule by choosing the no action alternative."