Comment Analysis · Docket FS-2025-0001

FS-2025-0001-260673

Opposes rescissionA2 moderateSubstance 10/24Owed an answerPosted August 23, 2026 On Regulations.gov

In short: The comment places on the record specific site-specific concerns regarding the rescission of the Roadless Area Conservation Rule for named forests in Georgia, North Carolina, Alaska, and Montana, arguing that the agency's purpose statement forecloses NEPA-required comparisons and requesting a reasoned explanation for reversing prior factual findings.

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

A2 moderate: Hard to dismiss — it shows cause and effect.

Owed an answer on Analytical gap.

Standard dismissals it defeats

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.

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.
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.
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

Wildlife Habitat
- “appreciate its function as a wildlife corridor”
- “appreciate the black bear habitat and wildlife corridors provided”
- “roads fragmenting habitats and isolating populations”
- “wild bison need places to roam outside of the parks”
Environmental Protection Biodiversity
- “in opposition to the rescission of the 2001 Roadless Area Conservation Rule”
- “roads are some of the most destructive things we can build in terms of harming wild animals”
- “noise pollution that interrupts feeding and breeding”
- “introducing more humans into areas where wild animals had more of a haven”
Legal Regulatory Framework
- “A purpose written as deregulation forecloses the comparison NEPA requires”
- “An agency reversing its own factual finding owes a reasoned explanation for the change”
- “analyze in the DEIS an alternative that retains the 2001 rule's protections”
- “provide a reasoned explanation for it on the record”
Economic Impact Fiscal
- “so much backlog of expensive road maintenance projects”
- “How is this prudent financially or in terms of labor power and resources”
- “adding to the trillions of dollars in U.S. national debt”

What it names

National Forests: Chattahoochee National Forest Chugach National Forest Chugach National Forest Tongass National Forest
Roadless areas: Boggs Creek

Attachments

1 file. Counts as 1 — Counts as one: The attachments enclose no one else's submissions; the comment counts as one.

Own letter

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapLegal

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I am a U.S. citizen and conservationist who is in opposition to the rescission of the 2001 Roadless Area Conservation Rule, and specifically about these inventoried roadless areas: - Boggs Creek (2,073 acres), Chattahoochee NF, Georgia (Appalachia Mountains) (I live here in Georgia and hike in the forests with my dog and appreciate its function as a wildlife corridor) - Bearwallow and other forests in Pisgah National Forests in NC (Appalachia Mountains) (I visit the Western North Carolina forests like Pisgah every summer to cool off from the Atlanta heat and love going on hikes with my family and appreciate the black bear habitat and wildlife corridors provided). - Chugach National Forest (5,439,110 acres), Chugach National Forest, Alaska (I loved getting to go to Alaska for conservation research in 2024 and hiking in the Chugach National forest. It’s gorgeous there. I didn’t get to see any grizzlies or moose there but I know they live there, and I love that). - Tongass National Forest near Glacier Bay NP and Juneau and Hoonah, Alaska (in visiting the Alaska Bay area for conservation research in 2024, I loved hiking around Hoonah on a Native Alaskan led wildlife tour and enjoying the forests around Juneau and Glacier Bay for photography and hiking – I saw my first ever wild coastal brown bear there! photo attached...we have enough roads to be able to see wildlife sometimes, but they need spaces away from vehicles too) - Bridger Teton and Custer-Gallatin in Montana near the National Parks (in visiting these park regions several times over the years, including in 2023 for conservation research, I learned from my interviewees just how important these forests are as wildlife corridors outside of the national parks like Yellowstone and Grand Teton to help eventually connect grizzlies from the greater yellowstone ecosystems up through the Glacier National Park/Blackfeet area and Canadian Rockies bear populations. These bears require large intact ecosystems to survive and thrive for longevity. And the wild bison need places to roam outside of the parks where they are less likely to get shot or run over. ) I ask that the agency disclose and analyze the site-specific environmental consequences of the proposed rescission for each of these areas, including the effects of the road construction and timber harvest it would newly allow. I raise the following issues for the record and ask that the agency respond to each of them: We already have enough public lands roads to wrap around the earth many times, and we have so much backlog of expensive road maintenance projects in our national forests already. How is this prudent financially or in terms of labor power and resources to maintain even more roads? Are you planning on expanding the federal government and its budget (adding to the trillions of dollars in U.S. national debt) to pay for and maintain more roads in national forests? In interviewing many conservation experts for my In Tune to Nature radio show, I have helped educate a lot of Americans about road ecology and corridor ecology, and I have seen the evidence that roads are some of the most destructive things we can build in terms of harming wild animals (and wild animals are not thriving - -most are declining) – from roads fragmenting habitats and isolating populations for mating and feeding, to getting hit by vehicles and causing accidents, to noise pollution that interrupts feeding and breeding, to other types of soil, water, and air pollution that harms wildlife and habitats, and to introducing more humans into areas where wild animals had more of a haven/refuge from interference and surveillance and attacks. From a utilitarian/cost benefit analysis, how are these roads beneficial to wildlife in comparison to how they are harmful and life-threatening? Wild animals are the major stakeholders in reality. Most major wildfires are started in human areas, where there are roads, so building more roads is likely to increase wildlife risks not reduce them. A purpose written as deregulation forecloses the comparison NEPA requires. I ask that the agency restate the purpose and need in terms of forest conditions and analyse at least one protective alternative in full. An agency reversing its own factual finding owes a reasoned explanation for the change. I ask that the agency identify the evidence for the reversal and respond to its own prior finding. I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule’s protections for the areas named above. 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, Carrie P. Freeman, PhD Atlanta, GA 30316