Comment Analysis · Docket FS-2025-0001

FS-2025-0001-272309

Opposes rescissionA0 noneSubstance 10/24Posted August 26, 2026 On Regulations.gov

In short: The comment documents that the agency is ignoring available scientific data on the ecological integrity of roadless areas in New Hampshire, Pennsylvania, West Virginia, and Minnesota, specifically regarding migratory bird habitat requirements and watershed protection under the Migratory Bird Treaty Act.

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

  • Wildlife Habitat
    • “wildlife habitat”
    • “migratory bird species require large interior forest tracts”
    • “fragmentation reduces patch size and breeding success”
    • “sustain key refugia for biodiversity”
  • Water Quality Quantity
    • “Clean water is most closely linked to undisturbed natural ecosystems”
    • “water quality and biodiversity decline as hydrological integrity is lost”
    • “heavily sediment-laden streams”
    • “Protecting watersheds”
  • Environmental Protection Biodiversity
    • “intact reference landscapes”
    • “ecological integrity”
    • “functional soils, hydrology, and food webs”
    • “Don't strip out protections”

What it names

Works cited
10.1098/rspb.2020.316410.1126/science.aaf716610.2489/jswc.66.3.78a

Attachments

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

  • Own letter
  • Own letter
  • Own letter
  • Own letter
  • Supporting material
  • Supporting material
  • Own letter
  • Supporting material

The comment

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

Dear Chief Schultz: As a wildlife biologist, I understand that not every decision can wait for perfect information. But this one has better-than-adequate information. The Department is choosing not to use it. I have spent time in roadless areas in New Hampshire, Pennsylvania, West Virginia, and Minnesota. They not only provide valuable ecosystem services and wildlife habitat but also a connection to the land for millions of people. Land that belongs to the American people. It is the soul of the country. This is why I'm filing this comment. The rule should stay. Intact roadless landscapes support functional soils, hydrology, and food webs that fragmented forests cannot replicate. Roadless areas function as intact reference landscapes. Roadless areas retain levels of ecological integrity that roaded landscapes have lost. (USDA Forest Service 2000; Talty et al. 2020). — USDA Forest Service, 2000 (https://www.fs.usda.gov/sites/default/files/roadless/roadless-feis-volume1.pdf) Many migratory bird species require large interior forest tracts. Minimum forest patch size for breeding viability varies by species but is large for many: 350 hectares for Ovenbird, 500–900 hectares for Acadian Flycatcher, and over 500 hectares for Kentucky Warbler. Fragmentation reduces patch size and breeding success simultaneously, and many migratory bird species are sensitive to both (USDA Forest Service 2009). — USDA Forest Service, Northern Research Station, 2009 (https://research.fs.usda.gov/treesearch/download/19723.pdf) These birds do not recognize political or international boarders. We have an obligation to protect them as do other countries in North America. Hence the Migratory Bird Treaty Act. The Roadless Rule supports our role in this international treaty. More than half of North American migratory bird species are declining. Population declines are widespread among North American migratory birds. The Connecticut Warbler has declined 62 percent since 1966; the Cerulean Warbler is declining at roughly 4.4 percent per year; the Golden-winged Warbler has lost an estimated 22 percent of its Great Lakes habitat and 43 percent of its Appalachian habitat since the 1960s. Habitat fragmentation on breeding grounds is documented as a major contributor (Hallworth et al. 2021; NRCS 2016). — Michael T. Hallworth, Erin Bayne, Emily McKinnon, Oliver Love, Junior A. Tremblay, Bruno Drolet, Jacques Ibarzabal, Steven Van Wilgenburg, Peter P. Marra, 2021 · Proceedings of the Royal Society B: Biological Sciences (https://doi.org/10.1098/rspb.2020.3164) “The planet’s remaining large and ecologically important tracts of roadless areas sustain key refugia for biodiversity and provide globally relevant ecosystem services. — Ibisch, P.L., Hoffmann, M.T., Kreft, S., Pe'er, G., Kati, V., Biber-Freudenberger, L., DellaSala, D.A., Vale, M.M., Hobson, P.R., Selva, N., 2016 · Science (https://doi.org/10.1126/science.aaf7166)” “Clean water is most closely linked to undisturbed natural ecosystems. When undisturbed watersheds in roadless and protected areas are fragmented by roads, logging, and intensive recreation development, both water quality and biodiversity decline as hydrological integrity is lost. The roaded, intensively managed landscapes of other national forest lands have been closely correlated with heavily sediment-laden streams and dramatic changes in flow regimes. — Dominick A. DellaSala, James R. Karr, David M. Olson, 2011 · Journal of Soil and Water Conservation (https://doi.org/10.2489/jswc.66.3.78A)” Rescinding the Roadless Rule opens these lands to private interest. Private industry works for private profit not public good. Protecting watersheds, species of concern, and forest integrity is an obligation of the federal government and your agency. Don't strip out protections that took a generation to build. With conviction, CommentID: RLC-20260826-F5WP4F

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