Comment Analysis · Docket FS-2025-0001

FS-2025-0001-300061

Opposes rescissionA0 noneSubstance 3/24Posted September 1, 2026 On Regulations.gov

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

  • Environmental Protection Biodiversity
    • “Old-forest structure takes a century or more to recover”
    • “biodiversity that depends on old-forest structure does not return on management-relevant timescales”
    • “unique and threatened creatures that call this place home”
    • “bastions of the natural world”
  • Recreation Tourism Public Use
    • “treasure the beauty, recreation, and history that these areas maintain”
    • “Thousands of people from across the United States and the world have taken in these falls in awe”
    • “connection is a function of the landscape's roadless character”
    • “exist, as closely as possible, outside of the bustle and noise of cities”
  • Climate Carbon Storage
    • “maintaining roadless protections is critical to climate-adaptation connectivity strategies”
    • “climate-adaptation connectivity strategies for wide-ranging species”

What it names

National Forests
Ozark-St. Francis National Forest
Works cited
10.3390/biosphere2010001

The comment

Dear Secretary Brooke L. Rollins and the USDA: For someone who has spent thousands of hours in roadless country, I don't need a policy brief to understand what could and would be lost here — I've been in these places more than most, and I know what makes them what they are. Roadless regions are bastions of the natural world; regions in which we can exist, as closely as possible, outside of the bustle and noise of cities. These places are rare and sparse - I have to travel more than an hour, frequently multiple hours, to reach the nearest ones. And yet I do so, frequently, because I treasure the beauty, recreation, and history that these areas maintain. The Penhook Special Interest Area contains several of the most spectacular and best known waterfalls in the southeastern Ozarks. Each of them is truly magnificent to behold, and there is no way in which the region would not be severely tarnished through the creation of roads within this area. Thousands of people from across the United States and the world have taken in these falls in awe. That connection is a function of the landscape's roadless character; the proposal, by undermining the Rule that preserves that character, would undermine the connection along with it. Regarding the Penhook in the Ozark-St. Francis National Forest, Arkansas:

Rescinding the Roadless Rule would open the Penhook, Ozark-St. Francis 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. Old-forest structure takes a century or more to recover. Old forests contain snags, fallen logs, and multi-layered canopies that support distinct plant and animal communities. Commercial harvest removes these structural features, and recovery to pre-harvest structural conditions takes 100 years or more. The biodiversity that depends on old-forest structure does not return on management-relevant timescales (Quinby 2026; Duflot et al. 2025). — Quinby, Peter A., 2026 · Biosphere (https://doi.org/10.3390/biosphere2010001) The Penhook Special interest Area of Arkansas stands for much more than what I can share in a single comment; thousands of people have traveled themselves in these undisturbed lands, not to mention the unique and threatened creatures that call this place home. There is too much that stands to be lost. “Identifies the most "natural" (least human-modified) corridors between large protected areas in the U.S. Many of the highest-priority corridors fall within or overlap inventoried roadless areas, providing direct evidence that maintaining roadless protections is critical to climate-adaptation connectivity strategies for wide-ranging species. — Research - Connectivity” The Department is respectfully requested to deny rescission and preserve the Rule's protections for inventoried roadless areas. Regards, Travis Howk

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