Comment Analysis · Docket FS-2025-0001

FS-2025-0001-261240

Opposes rescissionA2 moderateSubstance 12/24Owed an answerPosted August 23, 2026 On Regulations.gov

In short: The comment documents that the Dismal Creek IRA in the Ozark-St. Francis National Forest contains critical habitat for endangered bat species and supports birding-based economic activity, and asserts that the administrative record lacks a reasoned basis for rescission because the DEIS fails to analyze specific impacts on birding conditions and local economies.

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, Evidence.

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
    • “Interior Hardwood Forest Habitat for Bat Roosts and Breeding”
    • “essential for three federally endangered bat species”
    • “Inventoried roadless areas function as biological strongholds and refuges for many species”
  • Recreation Tourism Public Use
    • “hiking, fishing and exploring these ares”
    • “Degraded birding quality in the Dismal Creek IRA translates directly to lost economic activity”
    • “unmanaged recreation, including impacts from OHVs, as one of four key threats”
  • Governance Policy Process
    • “The administrative record does not supply a reasoned basis for rescission”
    • “The DEIS must analyze how road construction degrades the specific qualities”
    • “Department should decline to rescind”
  • Water Quality Quantity
    • “pristine clear turquoise waters”
    • “water quality”
    • “watershed and habitat degradation”

What it names

National Forests
Ozark-St. Francis National Forest
Roadless areas
Dismal Creek

Attachments

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

  • Supporting material

The comment

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

Dear Brooke L. Rollins, As a parent, my objection to this rescission is grounded in the same thing that grounds most of my parenting: a refusal to let short-term convenience substitute for long-term responsibility. As a parents who’s own parents got me out into nature and still enjoy all the wonderful and diverse habitats and nature our country has to offer well into their 70s, I am writing to urge you to do what’s right so my own children can also enjoy these areas into their senior years. We have spent time hiking, fishing and exploring these ares and the pristine clear turquoise waters. The Rule has enabled the preservation of places whose value to the public is illustrated by accounts like the one above; the Department should not dismantle that framework without compelling justification — and none has been offered. Regarding the Dismal Creek in the Ozark-St. Francis National Forest, Arkansas: Interior Hardwood Forest Habitat for Bat Roosts and Breeding — The Dry-Mesic Oak-Hickory and Shortleaf Pine-Oak forests within this 9,160-acre area provide unbroken canopy and mature tree structure essential for three federally endangered bat species: the Gray bat (*Myotis grisescens*), Indiana bat (*M… Degraded birding quality in the Dismal Creek IRA translates directly to lost economic activity. Fewer visitors means less spending on guides, outfitters, lodging, meals, and equipment in surrounding communities. Road construction doesn't just diminish a recreational experience — it eliminates revenue that local economies depend on. The economic harm is proportional to the recreational harm and equally permanent. The DEIS must analyze how road construction degrades the specific qualities that support birding in the Dismal Creek IRA — solitude, natural soundscape, water quality, wildlife habitat, and backcountry character — and assess the resulting decline in recreational quality and visitation. A generic statement about recreation impacts is insufficient; the analysis must address birding conditions in this specific area. "Of the nation's species currently listed as threatened, endangered, or proposed for listing under the ESA, approximately 25% of animal species and 15% of plant species are likely to have habitat within inventoried roadless areas (IRAs) on National Forest System lands. Inventoried roadless areas function as biological strongholds and refuges for many species." — USDA Forest Service “In 2004, Forest Service Chief Dale Bosworth named unmanaged recreation, including impacts from OHVs, as one of four key threats facing the nation's forests and grasslands. Unmanaged motorized use, particularly OHV use, has resulted in soil erosion, watershed and habitat degradation, spread of disease and impacts to cultural resource sites. — USDA Forest Service (https://www.nfwf.org/sites/default/files/norcal/Documents/SRNFEIS.pdf)” “Of the nation's species currently listed as threatened, endangered, or proposed for listing under the ESA, approximately 25% of animal species and 15% of plant species are likely to have habitat within inventoried roadless areas (IRAs) on National Forest System lands. Inventoried roadless areas function as biological strongholds and refuges for many species. — USDA Forest Service (https://www.nfwf.org/sites/default/files/norcal/Documents/SRNFEIS.pdf)” The administrative record does not supply a reasoned basis for rescission; accordingly, the Department should decline to rescind. With thanks, Laura Gahan CommentID: RLC-20260824-3QVLLX

Keep learning. Keep speaking up.The Roadless Rule depends on public engagement. Share what you've learned.

© 2026 roadless.org - Defending America's Last Wild Forests

Privacy Policy|Questions or concerns? noroads@roadless.org|Follow us: @defendroadless