Comment Analysis · Docket FS-2025-0001

FS-2025-0001-262939

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

In short: The comment places on the record specific data regarding wildlife habitat dependency, forest fire frequency, and carbon sequestration potential in roadless areas, while challenging the accuracy of the Forest Service Chief's testimony regarding Wildland-Urban Interface proximity and asserting procedural deficiencies in the NEPA analysis for the Perch Lake area.

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
    • “57% of vulnerable U.S. wildlife species have suitable habitat in roadless areas”
    • “over half of America's vulnerable wildlife species depend on roadless area habitat”
    • “harm people, animals, and ecosystems”
  • Climate Carbon Storage
    • “western U.S. forests could sequester up to 5,450 Tg CO2e by 2099”
    • “high-carbon forests overlap with the highest concentrations of endangered-species critical habitat”
  • Legal Regulatory Framework
    • “Concerns about NEPA adequacy, cumulative-effects analysis, range of alternatives”
    • “NEPA is procedural — it tells agencies how to decide, not what to decide”
    • “Agencies must consider and respond to substantive comments”
  • Scientific Research Evidence
    • “Healey (2020) analysis using ~20 years of data found forests in roadless areas burned at similar frequencies”
    • “claims that road prohibitions harm forest health are not supported by evidence”
    • “GIS analysis by The Wilderness Society using the Forest Service's own data found the actual figure is just 2.8 million acres”

What it names

National Forests
Chequamegon-Nicolet National Forest
Roadless areas
09180 - Perch Lake

The comment

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

Dear Secretary Rollins and Chief Schultz: As a parent, I've found that what you protect matters less than whether you can explain to the people who come after you why you made the choice you made — and I couldn't explain this one. I already mourn so many things about our natural world that my child won't get to experience, and I cannot let our national parks be one of those things. Camping, hiking and just exploring in nature have enhanced so much of my life, and it is our responsibility to preserve and expand our natural spaces for generations that will be here long after we are gone. That narrative is not submitted to substitute for technical analysis but to complement it — to provide the Department with a grounded account of what the Rule has protected and what rescission would jeopardize. Regarding the 09180 - Perch Lake in the Chequamegon-Nicolet National Forest, Wisconsin: Concerns about NEPA adequacy, cumulative-effects analysis, range of alternatives, and other procedural requirements the DEIS must satisfy. NEPA is procedural — it tells agencies how to decide, not what to decide. The National Environmental Policy Act requires federal agencies to analyze the environmental effects of major actions and to consider reasonable alternatives before deciding. The public comment period is the statutorily designated moment for outside parties to put information on the record. Agencies must consider and respond to substantive comments (CEQ 1997). — Council on Environmental Quality, 1997 (https://ceq.doe.gov/docs/ceq-publications/nepa25fn.pdf) Rescinding the Roadless Rule would open the 09180 - Perch Lake, Chequamegon-Nicolet National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. Rescinding the roadless rule would harm people, animals, and ecosystems across the world, and the short term financial gains of a few people are poorly vailed and illogical argument for removing the roadless rule. 57% of vulnerable U.S. wildlife species have suitable habitat in roadless areas - over half of America's vulnerable wildlife species depend on roadless area habitat Healey (2020) analysis using ~20 years of data found forests in roadless areas burned at similar frequencies as roaded areas - claims that road prohibitions harm forest health are not supported by evidence Buotte, Law, Ripple & Berner (2020) found western U.S. forests could sequester up to 5,450 Tg CO2e by 2099 — about 20% of global temperate/boreal forest mitigation potential — and these high-carbon forests overlap with the highest concentrations of endangered-species critical habitat. Forest Service Chief Tom Schultz testified to the Senate that 24.5 million acres of inventoried roadless areas are within one mile of the Wildland-Urban Interface (WUI)—calling it "our primary concern." A GIS analysis by The Wilderness Society using the Forest Service's own data found the actual figure is just 2.8 million acres—a nearly ninefold exaggeration. Less than 5% of inventoried roadless area acreage is in close proximity to the WUI, not 42% as Schultz claimed. The administration has 23.3 million acres of non-roadless forest land already available near the WUI for fuel reduction—without ever touching a roadless area. The 2001 Rule should remain operative; the Department is urged to hold that position. Warm regards, Jill Ghilardi CommentID: RLC-20260824-OWWDXB

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