Comment Analysis · Docket FS-2025-0001

FS-2025-0001-304204

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, including the lack of a projection for habitat fragmentation across 40.1 million acres, the absence of carbon storage analysis under harvest and roading, and the failure to identify mitigation for 327 ESA-listed species, while requesting that the agency quantify these impacts, complete ESA consultation, and analyze an alternative retaining the 2001 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 am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule. I grew up in West Virginia, wild and wonderful, and fostered a great love and appreciation for nature. I love walking in the forest hearing birds and seeing white tailed deer. The mountains are breath taking and it makes me proud to be from such a beautiful state. I have watched nature documentaries of our national parks as I have yet to be out west to see all the amazing wildlife out there but I would like to have the chance to and removing the Roadless Rule takes that chance away from me. I love hiking because you never know what wildlife you are going to see and removing the roadless rule would making hiking more dangerous for hikers and campers because it increases the risk of flash flooding and landslides. It would take away the wildlife I get so excited to see and connect with on these hikes. It took years and millions of dollars to get Flint, Michigan clean drinking water. How are you going to provide the 60 million Americans clean drinking who currently rely on those national parks for their water. I do not want my tax money going towards destroying wildlife and creating expensive problems down the line. I want my money going towards helping others and giving nature a chance to recover from climate change. This is not responsible management of public land. This will destroy the land making it unusable for anyone. Proper management is ensuring the land will be around for generations to come and enjoy. You claim this will decrease wildfire risks but science says it will actually increase the risk 4x. Habitat fragmentation is some of the worst land management practices one can do and that is what adding roads to the national parks does. 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. Wildlife does not want roads, mines, and timber plants. 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. 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. 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, Anna, WV