Comment Analysis · Docket FS-2025-0001

FS-2025-0001-337675

Opposes rescissionA2 moderateSubstance 12/24Owed an answerPosted September 8, 2026 On Regulations.gov

In short: The comment establishes that the DEIS fails to apply its own cited scientific findings on bird abundance, habitat fragmentation, and carbon storage to the specific 40.1 million acres of roadless areas affected by the rescission, and documents the specific acreage of the Ellicott Rock roadless areas in Sumter National Forest, South Carolina, that would be impacted.

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

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

Wildlife Habitat
- “quiet still belongs to birds”
- “bird richness declines with road presence”
- “31 percent of species avoiding the noise entirely”
- “Red-tailed Hawks, Sharp-shinned Hawks, Prothonotary Warblers”
Environmental Protection Biodiversity
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
- “apply it to the 40.1 million acres of inventoried roadless land”
- “fragmentation problem is similarly unresolved”
- “protect our common home”
Climate Carbon Storage
- “inventoried roadless areas contain about 5 percent of the stored forest carbon”
- “roughly 0.9 billion metric tons”
- “quantify the change in carbon storage and sequestration”
- “no examination of what harvest and roading would actually do to that figure”
Water Quality Quantity
- “part of a watershed system”
- “supplies 378 municipal water intakes”
- “watersheds containing affected roadless areas”
- “protect those intakes”

What it names

National Forests: Sumter National Forest
Roadless areas: Ellicott Rock 1Ellicott Rock 2

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 The peace I found camping in the wild at Ellicott Rock is not abstract. It is the specific quiet of a Southern Appalachian forest where roads have not yet arrived, and where that quiet still belongs to birds. South Carolina holds 6 inventoried roadless areas totaling 7,598 acres, and two of them, each parcel of the Ellicott Rock area within Sumter National Forest, are part of what this rescission would unravel. Ellicott Rock 1 covers 301 acres. Ellicott Rock 2 covers 517 acres. Both deserve what the 2001 Roadless Area Conservation Rule has provided. I oppose the rescission. South Carolina draws people precisely because of its natural resources, and among those resources the variety of birds is remarkable. The forest holds them: Red-tailed Hawks, Sharp-shinned Hawks, Prothonotary Warblers, Pileated Woodpeckers, residents and migrants alike. The agency's own environmental review does not protect what it cites. The DEIS acknowledges that bird richness declines with road presence in forested habitat, and it cites road-noise experiments showing that bird abundance dropped by over a quarter, with 31 percent of species avoiding the noise entirely. These are the agency's own cited findings. Yet nowhere does the document project what opening these roadless areas to road construction would mean for the species that use them. The connection between cited science and actual decision runs dry. I ask that the agency explain, with specificity, how the bird populations that depend on the roadless areas in South Carolina will be affected under each alternative, and that it place a substantive answer in the record. The fragmentation problem is similarly unresolved. "The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent." That range is wide and consequential. No projection applies it to the 40.1 million acres of inventoried roadless land that would be affected by this rescission. Citing a finding and then declining to apply it is not analysis. I ask that the agency carry that fragmentation range forward and apply it to the 40.1 million acres of potentially affected environment before any final decision is made. The carbon accounting has the same problem. "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 document then concludes that these lands will continue to sequester and store carbon, with no examination of what harvest and roading would actually do to that figure under the alternatives being considered. A conclusion reached without calculation is not a conclusion. The agency must quantify the change in carbon storage and sequestration under each alternative. The agency's stated rationale for rescission, that state-specific approaches can serve as adequate substitutes for a national rule, has a history the document does not honestly confront. The record states that the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's "inflexible 'one-size-fits-all' nationwide rulemaking approach." 70 Fed.Reg. at 25,656. That dissatisfaction did not survive judicial review the last time this agency dismantled the national rule in favor of state-by-state management, and the Ninth Circuit identified specific deficiencies in that approach. The agency's prior finding that local decision-making can incrementally erode nationally significant roadless values is part of that record. This proposal does not explain how it avoids those same deficiencies. I ask that the agency provide a direct answer to that question. We must protect our common home. The roadless areas in South Carolina, including the forest around Ellicott Rock where I camped, are part of a watershed system that, across the Southern region alone, supplies 378 municipal water intakes sitting in watersheds containing affected roadless areas. The agency has not demonstrated that state-level management will protect those intakes, those birds, or those forests with anything approaching the reliability the current national rule provides. The rescission should not proceed. Sincerely, Christopher Hall Aiken, South Carolina