Comment Analysis · Docket FS-2025-0001

FS-2025-0001-274880

Opposes rescissionA3 weakSubstance 14/24Owed an answerPosted August 27, 2026 On Regulations.gov

In short: The comment establishes that the agency's proposal to rescind the 2001 Roadless Area Conservation Rule lacks adequate analysis of karst hydrology impacts, fails to reconcile wildfire ignition data with the rescission, presents an economic analysis that does not establish a net benefit, and improperly certifies no significant impact on small entities without assessing local outfitters and guides.

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

A3 weak: Substantive, but easier to set aside.

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.
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.
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.
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

Water Quality Quantity
- “Alexander Springs is crystal clear water”
- “Ocala sits directly on top of the Floridan Aquifer”
- “Road construction through karst is a direct contamination pathway to that water supply”
- “378 municipal water intakes sit in watersheds containing affected roadless areas”
Wildlife Habitat
- “Red-cockaded woodpeckers recovered here... because the longleaf pine stands they need have never been fragmented by roads”
- “bird richness declines with road presence in forested habitat”
- “roads built for oil extraction may have altered mule deer migration routes”
- “I have also seen deer, hogs, bear, and otters in this forest”
Recreation Tourism Public Use
- “I am one of the roughly 2 million people who visit Ocala National Forest every year”
- “I backpack that trail through country that includes the Alexander Springs Creek roadless area”
- “I go to Farles Prairie in the early morning to photograph birds”
- “want to continue to have a wilderness experience”
Economic Impact Fiscal
- “The economics of this proposal do not hold together”
- “recreation losses of at least $6.1 million a year”
- “net present value spanning -$92 million to +$199 million”
- “road system already carrying a $6.9 billion maintenance backlog”

What it names

National Forests: Ocala National Forest
Roadless areas: Alexander Springs CreekFarles Prairie
Works cited: Kroeger et al. 2022

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Florida National Scenic Trail is one of 11 National Scenic Trails in the entire United States. Just 11. I am one of the roughly 2 million people who visit Ocala National Forest every year, and I backpack that trail through country that includes the Alexander Springs Creek roadless area and Farles Prairie. I oppose rescission of the 2001 Roadless Area Conservation Rule. Alexander Springs is crystal clear water, 72 degrees all year. There is a short trail to the spring from the Florida National Scenic Trail, and it is pretty wonderful to stop by and cool off after a 10 mile hike. The Ocala sits directly on top of the Floridan Aquifer, and Alexander Springs, a first-magnitude spring in the heart of the forest, pumps 80 million gallons of water per day through karst limestone. Across the Southern region, which includes Florida, 378 municipal water intakes sit in watersheds containing affected roadless areas. Road construction through karst is a direct contamination pathway to that water supply, and I ask that the agency explain specifically what analysis it performed of construction impacts on karst hydrology before advancing this proposal. I go to Farles Prairie in the early morning to photograph birds. I like seeing the marked longleaf pines where the red-cockaded woodpecker lives. Red-cockaded woodpeckers recovered here from 7 breeding pairs to 98 family groups because the longleaf pine stands they need have never been fragmented by roads. The agency's own record states that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. (source: DEIS; Kroeger et al. 2022; McClure et al. 2013; Ware et al.) I have also seen deer, hogs, bear, and otters in this forest. The DEIS cites Wyoming research finding roads built for oil extraction may have altered mule deer migration routes and increased their movement speed, and the agency's own analysis says the danger is disrupted migration and lost unroaded security. The agency owes this record a specific response to what road construction in these areas would mean for species that have recovered precisely because the land stayed unroaded. The roads I cross backpacking are mostly sugar sand. Building roads to access timber would require far more than a sugar sand road, and the trucks that followed would bring more noise, smell, and pollution. No one has gone out hiking and backpacking in the forest and said, gee, if only there were more roads it would be better. The agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal justifies rescission in part on wildfire and fuels management grounds. I ask that the agency reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. The economics of this proposal do not hold together. The agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. The agency should explain how an action whose own analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog. The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. That certification was reached by spreading losses across every small firm in the sector nationally rather than assessing the outfitters and guides actually holding permits in the affected areas. The agency should withdraw the certification and assess the small entities actually operating in the potentially affected roadless areas. Finally, the proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. This comment is such an interest. I visit and backpack through the Ocala National Forest and want to continue to have a wilderness experience. Public lands should be managed for the public to use, to enjoy, to find a calm place to relax, not to benefit companies exploiting the forest. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. Sincerely, Elizabeth Lambert Dade City, Florida