Comment Analysis · Docket FS-2025-0001

FS-2025-0001-609490

Opposes rescissionA0 noneSubstance 8/24Posted October 7, 2026 On Regulations.gov

In short: The comment establishes the commenter's standing as a former wildland fire technician and resident of the Plumas National Forest, and documents their opposition to the Roadless Rule changes based on personal experience with wildfire ignition patterns and recreational use of roadless areas.

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
- “habitat, biodiversity, and recreational opportunities”
- “wealth of habitats”
- “impact more roads will have on game, fish”
Recreation Tourism Public Use
- “cherished the solitude roadless areas provide”
- “recreational opportunities that attract people precisely because these areas are roadless”
- “experience the United States as it existed during a time of awe, wonder”
Forest Management Wildfire
- “human-caused fires start in parts of the national forest accessible by road”
- “Making it easier for people to access unburned forest will not reduce the risk of wildfire”
- “wildfire proliferation”
Governance Policy Process
- “voices are notably absent from this proposal”
- “free from the partisanship and influence of local politics”
- “purpose of a federal rule is to provide stability and measured stewardship”

What it names

National Forests: Plumas National Forest

The comment

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

Dear Department of Agriculture, I write as a former wildland fire technician, fly fishing guide, and businessman who has worked and recreated on national forests from California to Montana, and I write in opposition to the proposed changes to the Roadless Rule. As someone born on the Plumas National Forest who has camped, fished, and made a living on public lands, I've never had trouble finding an existing Forest Service road to reach my destination, and I've cherished the solitude roadless areas provide. I wish to address the Department's stated reasons for this proposed change and illustrate why I think it's crucial to keep the quarter of total acreage the Forest Service oversees subject to the national guidelines the roadless rule protects. First, the Department can only cite the current President's executive orders and declarations as the purpose behind this proposal. Ultimately the federal government exists through funding from and a social contract with its citizens, yet their voices are notably absent from this proposal. Nowhere do we hear from loggers, anglers, hunters, backpackers, foresters, firefighters, ranchers, or the myriad of other stakeholders who could inform the proposed changes. Second, the Department estimates the proposed rule change could lead to an increase in revenue of $5-10 million dollars for the Treasury and Forest Service, a sliver of the $12 billion net spending for the Forest Service last year. The current document fails to provide solid background in support of the proposed change, and any revenue will vanish in the increased cost of maintaining more roads and litigating the myriad of lawsuits sure to follow this change. Second, I would suggest existing roadless areas offer more value than they cost in the form of habitat, biodiversity, and recreational opportunities that attract people precisely because these areas are roadless. At a time when it feels impossible to escape the spread of cities and screens, roadless areas provide an unparalleled opportunity for citizens to experience the United States as it existed during a time of awe, wonder, and respect for this land's wealth of habitats, a tradition passed down through President Theodore Roosevelt. A change of this nature can only lead to one outcome: more roads. For more on the impact more roads will have on game, fish, and wildfire proliferation, see Ben Goldfarb's book called Crossings. As a former wildland fire technician, I witnessed the vast majority of human-caused fires start in parts of the national forest accessible by road. Where humans go, fires follow. Making it easier for people to access unburned forest will not reduce the risk of wildfire; if anything, it may only increase it. While the proposal purports to empower local Forest Service officials, the purpose of a federal rule is to provide stability and measured stewardship to public lands free from the partisanship and influence of local politics (of any persuasion) that can infiltrate local ranger stations. We have a saying in Montana: if it ain't broke, don't fix it. The Roadless Rule isn't broken, and the fix is to leave it the way it is.