Comment Analysis · Docket FS-2025-0001

FS-2025-0001-282467

Opposes rescissionA2 moderateSubstance 12/24Owed an answerPosted August 28, 2026 On Regulations.gov

In short: The comment places on the record specific data from the agency's own DEIS and Cost Benefit Analysis—regarding bird abundance, fire density, and net present value—to document internal contradictions in the agency's justifications for rescinding the Roadless Area Conservation Rule and to request an explanation of how the proposal reconciles these findings with its stated benefits.

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
- “bird richness declines with road presence”
- “road-noise experiments... cut bird abundance by over a quarter”
- “forests I travel for birds depend on that protection”
- “31 percent of species avoiding the noise entirely”
Forest Management Wildfire
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “DEIS Table 21 reports higher fire density on roaded land”
- “rationale the agency's own record undermines directly”
- “expose those 68,987 acres to exactly the conditions... identified as harmful”
Economic Impact Fiscal
- “net present value ranging from -$92 million to +$199 million”
- “recreation losses of at least $6.1 million a year”
- “total timber volume affected by this rule is less than 0.5 percent”
- “road system already carrying a $6.9 billion maintenance backlog”
Recreation Tourism Public Use
- “My birding, hiking, paddling, camping”
- “outfitters, guides and tour operators as affected”
- “reconnect with nature”
- “protected public land matters”

What it names

National Forests: Chequamegon-Nicolet National Forest

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 Public lands are sacred to me. I hike throughout Wisconsin on both state and nationally managed lands, including Horicon National Wildlife Refuge and Apostle Islands National Lakeshore, and the Chequamegon-Nicolet National Forest, and birding has taken me further still, into protected waterways and old-growth forests across publicly managed land. I started birding as a way to reconnect with nature in my city, and the hunt for rarer birds has deepened my understanding of why protected public land matters. That understanding is why I oppose the rescission of the 2001 Roadless Area Conservation Rule. Wisconsin holds 16 inventoried roadless areas totaling 68,987 acres, and the forests I travel for birds depend on that protection. The agency's own draft environmental impact statement acknowledges 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. Roads do not merely fragment physical space; the noise alone restructures which species can persist. The rescission would expose those 68,987 acres to exactly the conditions the agency's own cited science identifies as harmful. I ask the agency to explain, specifically, how this body of evidence in its own DEIS supports expanding the road network into the roadless areas where I go to find birds. The proposal also invokes wildfire management as justification, a rationale the agency's own record undermines directly. The DEIS 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." DEIS Table 21 reports higher fire density on roaded land than inside the affected roadless areas. The agency must reconcile this rescission with those ignition findings and explain on the record why its stated wildfire rationale survives its own data. The economic case is no stronger. The agency's own record acknowledges that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against that baseline, the Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service while booking recreation losses of at least $6.1 million a year, yielding a net present value ranging from -$92 million to +$199 million. That range cannot establish a net benefit, yet the agency proposes to expand a road system already carrying a $6.9 billion maintenance backlog. The agency must explain how a proposal whose own analysis cannot confirm positive net value justifies that expansion. The small-business certification compounds the problem. 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 conclusion was reached by spreading losses across every small firm in the sector nationally rather than assessing the permits actually held in affected areas. The certification should be withdrawn and the impact assessed on the firms actually operating in those 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. My birding, hiking, paddling, camping and my travel to places like the Chequamegon-Nicolet, and my choices about where to go are built on the continued protection this rule provides. Under the legal obligation to assess reliance interests when changing course, the agency must identify and weigh the interests described in the comments it receives, including this one. Sincerely, Kai