Comment Analysis · Docket FS-2025-0001

FS-2025-0001-300805

Opposes rescissionA2 moderateSubstance 10/24Owed an answerPosted September 2, 2026 On Regulations.gov

Campaign — One letter sent by 10 or more people, copied or lightly reworded. One of 12 submissions in its group; the sender added words of their own. See the letter, its submissions and topics.

In short: The comment places on the record specific deficiencies in the DEIS analysis regarding habitat fragmentation, big game survival, carbon storage, and the lack of mitigation for 327 ESA-listed species, while requesting that the agency quantify these impacts, complete ESA consultation, and analyze an alternative retaining the 2001 Roadless Rule.

Scored with own additions — A family member whose own text beyond the shared letter was scored and combined with the letter's score.

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.

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”
- “likely to adversely affect 327 ESA-listed species”
- “unbroken habitat”
- “unblemished by roads”
Wildlife Habitat
- “elk survival rates increased during a road closure”
- “elk avoid roads and select unroaded habitat”
- “watch wildlife and birds”
- “project the effects on big game populations”
Climate Carbon Storage
- “holding carbon”
- “contain about 5 percent of the stored forest carbon”
- “quantify the change in carbon storage and sequestration”
- “0.9 billion metric tons”
Governance Policy Process
- “Every conservation alternative was eliminated by how the purpose was written”
- “forecloses the comparison NEPA requires”
- “restate the purpose and need”
- “analyse at least one protective alternative in full”

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 I look for and watch wildlife in many of our Florida natural areas. Deer and birds some of which are natural only to Florida in the US help show nature and drive people here for tourism. These areas make great camping and hiking areas. In order to camp and take in the great American outdoors, I have to drive many miles. Taking away these spaces makes it harder for average Americans to take in and value all of America. The trails also provide safe areas for families to bike and ride outside of roads where they may cause traffic issues if there is no bike lanes or sidewalks. They also help people stay healthy and active by allowing these hobbies to stay in shape or train to be professional athletes. The great American landscapes and parks drive millions of people to come from across the world to American communities and support all people. Having these photo worthy sights makes people believe in and have faith in America as a beautiful place to travel and visit. I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule. I raise the following issues for the record and ask that the agency respond to each of them: Issue 1: Fragmentation is quantified and not applied I go out to watch wildlife and birds, and what I look for lives in unbroken habitat. The agency measured what fragmentation costs and then set the finding aside. The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. The number appears; no projection across the 40.1 million affected acres follows. I ask that the agency apply the cited fragmentation range to the 40.1 million acres of potentially affected environment. Issue 2: Elk survival, in the agency’s own citation I watch wildlife, and the animals I go looking for need country roads have not reached. The agency's own citation makes that point better than I can. 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. No population-level effect on big game is projected anywhere in the document. I ask that the agency project the effects on big game populations and hunter opportunity. Issue 3: Carbon is stated and dropped The standing forests where I watch wildlife are doing quiet work the whole time, holding carbon. The agency states what these lands store and then drops the analysis. The DEIS cites the estimate that these inventoried roadless areas contain about 5 percent of the stored forest carbon in the coterminous United States, roughly 0.9 billion metric tons. The DEIS concludes these lands will continue to sequester and store carbon, with no analysis of harvest and roading. I ask that the agency quantify the change in carbon storage and sequestration under each alternative. Issue 4: The agency’s own assessments predict harm to 327 protected species I spend my time looking for wildlife in these forests, and the rarest of it is exactly what the agency's own assessments say this action is likely to harm. The agency’s 428-page draft biological assessment closes: “Rescinding the 2001 Roadless Rule will increase the likelihood of road construction and timber harvests occurring in locations previously considered inventoried roadless areas. In many cases the Forest Service anticipates this increased activity to adversely affect some ESA-listed species and their designated critical habitats.” The DEIS tallies the determinations: “may affect, likely to adversely affect” for 327 ESA-listed species and 71 designated critical habitats. Not may: will increase the likelihood, and the agency anticipates the harm. The phrase “likely to adversely affect” appears more than 150 times across the USFWS assessment alone, and the proposal identifies mitigation for none of it. I ask that the agency disclose, species by species, how the likely adverse effects its own biological assessments identify will be avoided or mitigated, and that ESA consultation be completed and published before any final rule. I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule’s protections. Where this proposal rests on factual conclusions that differ from the agency’s own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record. Sincerely, Matt Jansen Gainesville, Florida