Comment Analysis · Docket FS-2025-0001

FS-2025-0001-301764

Opposes rescissionA3 weakSubstance 8/24Owed an answerPosted September 2, 2026 On Regulations.gov

In short: The comment documents that the Bear Swamp IRA in Huron-Manistee National Forest contains 197 acres of Great Lakes Northern Pine-Oak Forest identified by NatureServe as habitat for the Indiana Myotis, and cites scientific evidence that road construction degrades wetland species diversity and bird densities, thereby establishing a specific ecological basis for opposing the rescission of the Roadless Rule.

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

  • Wildlife Habitat
    • “habitat for Indiana Myotis”
    • “Road construction degrades this ecosystem”
    • “destroying wildlife habitats”
    • “reduced densities near highways”
  • Environmental Protection Biodiversity
    • “fracturing ecosystems”
    • “Wetland species diversity is negatively correlated with paved-road density”
    • “Great Lakes Northern Pine-Oak Forest”
    • “rare federal protections that's working”
  • Recreation Tourism Public Use
    • “enjoyed exploring the many miracles of nature”
    • “Being outdoors in a natural, roadless environment”
    • “protect these spaces now so that many generations to come can experience the same joy”
  • Cultural Heritage Indigenous
    • “disrupt sacred and cultural sites”

What it names

National Forests
Huron-Manistee National Forest
Roadless areas
Bear Swamp

The comment

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

Dear Secretary and Chief: Climate-concerned citizen, late-night reader of EPA reports — I want the record to show a vote against rescinding one of the rare federal protections that's working. I have always enjoyed exploring the many miracles of nature this Earth has to offer. Being outdoors in a natural, roadless environment has many benefits for humanity, from physical to mental health. They are also great places to learn and find meaningful connections. What I've described took a long time to exist. It won't take long to destroy. The rule is what slows that down. I have countless lovely memories of traveling to national parks. I want to protect these spaces now so that many generations to come can experience the same joy that I have. Regarding the Bear Swamp in the Huron-Manistee National Forest, Michigan: Huron-Manistee National Forest's Bear Swamp IRA contains 5.0% coverage (~197 acres) of Great Lakes Northern Pine-Oak Forest (Laurentian-Acadian Northern Pine-(Oak) Forest) (GNR), which NatureServe independently identifies as habitat for Indiana Myotis (Myotis sodalis, G2). The species is separately documented present in the area. Road construction degrades this ecosystem and the imperiled species that depends on it. "Wetland species diversity is negatively correlated with paved-road density up to 2 km from wetlands. The effects of roads on wetland diversity take about 3-4 decades to be fully realized. Of 43 species of woodland breeding birds, 26 species (60%) showed reduced densities near highways, and traffic noise explained the most variation in bird density in relation to roads." — Transportation Research Board and National Research Council, 2005 The ecological association between Indiana Myotis (Myotis sodalis) and Great Lakes Northern Pine-Oak Forest (Laurentian-Acadian Northern Pine-(Oak) Forest) means road construction in Bear Swamp operates through a specific degradation pathway: roads alter the physical structure and ecological processes of the ecosystem, which in turn eliminates or degrades the habitat conditions the species requires. The 5.0% coverage (~197 acres) represents the spatial extent of this vulnerability. The rescission of the Roadless Rule will negatively impact the health of the planet by fracturing ecosystems, destroying wildlife habitats and potentially putting crucial species at risk of endangerment/extinction, and disrupt sacred and cultural sites. It would also negatively impact humanity by unnecessarily using up more of our already limited natural resources and spending unnecessary money on maintenance of the roads, etc. These lands deserve better than this. Thank you for your time and consideration. With hope, Sadie Schrodeder CommentID: RLC-20260902-V4TNM3

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