Comment Analysis · Docket FS-2025-0001

FS-2025-0001-334254

Opposes rescissionA0 noneSubstance 8/24Posted September 7, 2026 On Regulations.gov

In short: The comment establishes that the commenter, an ecologist residing in Illinois, has standing to oppose the rescission of the Roadless Area Conservation Rule based on the specific impact to 11,000 acres of inventoried roadless areas in Illinois (including Midewin Tallgrass Prairie and Shawnee National Forest) and the loss of future recreation opportunities in those specific locations.

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
- “biodiversity hotspots”
- “protect wildlife habitat for salmon, trout, elk”
- “protect old growth forest”
- “ecological value of these lands is extremely high”
Water Quality Quantity
- “protect drinking water sources”
- “intact forests filter water naturally”
- “clean drinking water”
- “60 million Americans rely on national forests for drinking water”
Forest Management Wildfire
- “wildfires are 4x more likely to start near roads”
- “roughly 90% of wildfires start within half a mile of a road”
- “mitigate our risk of wildfires”
- “directly rebuts the administration's stated rationale”
Climate Carbon Storage
- “help with carbon storage”
- “significant carbon storage”
- “contains vast swaths of the country's remaining old-growth forest”

What it names

National Forests: Gila National Forest Shawnee National Forest Tongass National Forest

The comment

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

My name is Samantha Berk. I work as an Ecologist for a living and in my spare time I am an avid hiker on public lands. I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I live in the state of Illinois which according to the USDA and Forest Service has 11,000 acres of inventoried roadless areas. These roadless areas include Midewin Tallgrass Prairie and Shawnee National Forest, both areas of which are the largest stretches of National Forest Systems Land in the state. Recinding the Roadless Area Conservation Rule would eliminate or put at risk already sparse National Forest Systems Land in the state, putting people, wildlife, and environmental health at risk of harm. As an ecologist, I know that the ecological value of these lands is extremely high, as these lands are biodiversity hotspots and provide valuable ecosystem services such as clean drinking water, flood buffers, and habitat for people and wildlife alike. This is not a unique perspective, as thousands of other Americans warn of similar negative consequences for the elimination and putting at risk of millions of acres of public land. Midewin Tallgrass Prairie and Shawnee National Forest are both lands that I have not yet had the pleasure of visiting and recreating in, and the recinding of the Roadless Area Conservation Rule would prevent me from enjoying and reaping benefits from. Hailed as one of America's most successful conservation measures, the Roadless Area Conservation Rule protects drinking water sources, wildlife habitat, and world-class recreation opportunities across 58.5 million acres of national forests. By recinding the Roadless Rule, this puts land in 39 states at risk of development and negative consequences, including 9 million acres of coastal rainforest in Alaska's Tongass National Forest, nearly a quarter of New Mexico's Gila National Forest, and 80,000 acres in Vermont's Green Mountain National Forest; all National Forest Systems Land that I wish to enjoy, recreate, and reap the ecological benefits (including clean drinking water) from. The Roadless Area Conservation Rule and our National Forest Systems Land protect our drinking water. 60 million Americans rely on national forests for drinking water, because intact forests filter water naturally. Without national forests, our public health is at risk of declining all the while we experience some of hottest temperatures on records and record breaking environmental disasters where clean water to our most vulnerable communities is becoming more scare. The Roadless Area Conservation Rule and our National Forest Systems Lands also protect wildlife habitat for salmon, trout, elk, and other species that depend on undammed, unlogged streams and connected landscapes. These animals are a vital food source for other wildlife and people who hunt for food in order to survive. The Roadless Area Conservation Rule and our National Forest Systems Land also mitigate our risk of wildfires because wildfires are 4x more likely to start near roads; roughly 90% of wildfires start within half a mile of a road — directly rebuts the administration's stated rationale. New research from The Wilderness Society (now in peer review) shows that from 1992-2024, wildfires were four times more likely to start in roaded areas than in roadless forest tracts. Another study by the Pacific Biodiversity Institute showed that over 90% of wildfires started within half a mile of a road. The Roadless Area Conservation Rule and our National Forest Systems Land also protect old growth forest and help with carbon storage because they contains vast swaths of the country's remaining old-growth forest and significant carbon storage. Finally, I would like to add that the existing road network already carries an $8.5+ billion maintenance backlog; building more roads adds to it, and in time where the national debt is only growing, not shrinking, it would be fically irresponsible to pursue more large-scale transportation projects, especially given the other reasons I listed above. For the reasons listed above, fully or partially rescinding the Roadless Rule under Alternatives 2 and 3 of the draft EIS would be a grave mistake. Again, I oppose the proposal to rescind or alter the Roadless Rule and I support Alternative 1, the No Action alternative.