Comment Analysis · Docket FS-2025-0001

FS-2025-0001-284408

Opposes rescissionA2 moderateSubstance 13/24Owed an answerPosted August 28, 2026 On Regulations.gov

In short: The comment documents that the agency's DEIS contains internal contradictions regarding wildfire risk and fails to quantify the biodiversity, big game, and water quality impacts of rescinding the Roadless Area Conservation Rule, specifically regarding the Wolfpen roadless area in the Daniel Boone National Forest.

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

Environmental Protection Biodiversity
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
- “home to the Indiana bat, the Virginia big-eared bat, the northern long-eared bat, the Kentucky arrow darter, and the blackside dace”
- “shelter more than 5,000 Virginia big-eared bats, roughly 40 percent of the global population of a federally endangered species”
Water Quality Quantity
- “headwater streams feed the Red River, Kentucky's only National Wild and Scenic River”
- “378 municipal water intakes sit in watersheds containing affected roadless areas”
- “connection between roadless protection and drinking water quality for communities downstream is not speculative”
Forest Management Wildfire
- “Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands”
- “explain why opening Wolfpen and areas like it to road building reduces fire risk rather than increasing it”
Recreation Tourism Public Use
- “do not want to see future generations lose the opportunity to have those experiences”
- “grew up running and playing in the Daniel Boone National Forest”
- “chosen to attend college at Morehead State University partially because of the gorgeous landscape and familiarity of the area”

What it names

National Forests: Daniel Boone 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 My Dad was born and raised in Salt Lick, KY and grew up running and playing in the Daniel Boone National Forest that was near his someplace. He took me there to explore the woods often when I was a child and I do not want to see future generations lose the opportunity to have those experiences. Even though I have not been fortunate enough to live nearby, it has always been an important part of my life, I even chose to attend college at Morehead State University partially because of the gorgeous landscape and familiarity of the area. Wolfpen is all Kentucky has. At 2,835 acres, it is the single inventoried roadless area in the entire state, and its headwater streams feed the Red River, Kentucky's only National Wild and Scenic River. Rescinding the 2001 Roadless Area Conservation Rule would put every acre of that into play for road construction and development. I oppose this proposal, and I ask the agency to answer several specific questions that its own draft environmental impact statement raises and then leaves open. The agency's stated rationale includes wildfire and fuels management. That justification is hard to square with the agency's own findings. 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." That is the agency's text, not mine. DEIS Table 21, according to the record, shows far higher fire density on roaded land than inside the affected roadless areas. The proposal does not explain why it departs from those findings. The agency must reconcile the rescission with its own ignition data and explain why opening Wolfpen and areas like it to road building reduces fire risk rather than increasing it. The agency also cites permitting complexity and administrative burden as reasons for rescission. The existing rule already contains exceptions. The agency's own description of the rule notes that it generally banned road building subject to limited exceptions, including for the preservation of existing rights and for Forest Service construction necessary for public health and safety. That language is the agency's, not a paraphrase. The proposal does not identify which specific burdens those exceptions fail to address. It does not quantify the administrative cost of working within the exceptions versus the environmental cost of eliminating the rule entirely. The agency should identify on the record which specific burdens fall outside the existing exceptions, including those covering public health, safety, and existing mineral leases, and should quantify them rather than assert them. Biodiversity loss is addressed numerically in the DEIS and then left hanging. The DEIS cites the finding that "habitat fragmentation reduces biodiversity by 13 to 75 percent." That range appears in the document. No projection of what it means across the 40.1 million acres of potentially affected environment follows. Wolfpen sits inside the Daniel Boone National Forest, home to the Indiana bat, the Virginia big-eared bat, the northern long-eared bat, the Kentucky arrow darter, and the blackside dace. The deep sandstone overhangs in the Red River Gorge shelter more than 5,000 Virginia big-eared bats, roughly 40 percent of the global population of a federally endangered species. Fragmentation of the habitat that buffers those areas carries real and specific consequences. The agency should apply the cited fragmentation range to the 40.1 million acres of potentially affected environment and explain what that means for species like those present in the Daniel Boone. Big game effects are similarly documented and then dropped. The DEIS cites the finding that "elk survival rates increased during a road closure and decreased when the gates were removed (Cole 1997), and that elk avoid roads and select unroaded habitat." The agency entered that finding into its own record and drew no population-level conclusion from it. No projection of effects on big game populations or hunter opportunity appears anywhere in the document. The agency should project those effects. Finally, the watershed dimension of this proposal deserves a direct answer. Across the Southern region, which includes Kentucky, 378 municipal water intakes sit in watersheds containing affected roadless areas. Wolfpen drains into the Red River. The connection between roadless protection and drinking water quality for communities downstream is not speculative. The agency should explain what analysis it performed regarding those 378 intakes and what protections, if any, replace the current rule for the communities they serve. Sincerely, Jeanetta Nixon Ashland, KY