Comment Analysis · Docket FS-2025-0001

FS-2025-0001-353023

Opposes rescissionA2 moderateSubstance 14/24Owed an answerPosted September 12, 2026 On Regulations.gov

In short: The comment establishes that the administrative record lacks site-specific analysis for Northern Myotis and quantified analysis of invasive-species spread associated with new road mileage in the Devil's Den 09083 Inventoried Roadless Area, citing specific data from the USFWS Biological Assessment and state wildlife agencies to document these deficiencies.

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, 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.
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
- “creating habitat for threatened and endangered species”
- “critical habitat that will be lost”
- “Northern Myotis (Myotis septentrionalis, G2)”
- “displace our native species that our insects and birds rely on”
Water Quality Quantity
- “threat to our water quality”
- “alters hydrology”
- “delivers chemical contaminants to adjacent habitats”
- “protect watersheds that deliver drinking water”
Environmental Protection Biodiversity
- “Construction inevitably introduces invasive plant species”
- “Roads create favorable conditions for invasive plants”
- “81 (60 percent) are threatened by invasive or non-native species”
- “IRAs often have less non-native invasive plants due to the lack of roads”
Recreation Tourism Public Use
- “I want to see it in its pristine state”
- “much less likely to visit a protected place that has been cut up with roads”
- “This land belongs to the public”
- “Don't sign it away”

What it names

National Forests: Green Mountain and Finger Lakes National Forests
Roadless areas: Green Mountain

The comment

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

Dear Secretary Rollins: I am an ecological landscape designer who spends my time studying and actively creating habitat for threatened and endangered species. We cannot afford to build roads through our protected landscapes. Not only because of the critical habitat that will be lost, but the threat to our water quality, and fire risk that road construction creates. Construction inevitably introduces invasive plant species which displace our native species that our insects and birds rely on. I have not yet had the chance to get to Devils Den, but it is high on my list of places to visit. I want to see it in its pristine state, not a damaged, disturbed version. I am much less likely to visit a protected place that has been cut up with roads. Regarding the Devil's Den 09083 in the Green Mountain and Finger Lakes National Forests, Vermont: Extreme or 71-100% pop. decline severity and not assessed scope characterize the impact of 8.1 - Invasive non-native/alien species/diseases on Northern Myotis (Myotis septentrionalis, G2) in the Devil's Den 09083 Inventoried Roadless Area, Green Mountain and Finger Lakes National Forests — losses that the current Roadless Rule helps constrain. Road construction in Devil's Den 09083 introduces sediment, alters hydrology, and delivers chemical contaminants to adjacent habitats — the direct physical drivers of 8.1 - Invasive non-native/alien species/diseases. The absence of site-specific analysis for Northern Myotis (Myotis septentrionalis) in the Devil's Den 09083 Inventoried Roadless Area, Green Mountain and Finger Lakes National Forests, constitutes a gap in the administrative record that exposes the final decision to legal challenge. The DEIS must evaluate 8.1 - Invasive non-native/alien species/diseases at the documented severity and scope. "In 2001, the Roadless Area Conservation Rule prohibited road construction and timber harvest in 240,000 km² of inventoried roadless areas (IRAs) located on United States Department of Agriculture Forest Service lands. Many IRAs are among the most wild, undeveloped areas both in the nation and within their respective states. IRAs increase the size of—and reduce isolation between—protected areas, likely buffering them from external stressors. In some places, IRAs protect watersheds that deliver drinking water to hundreds of thousands of people." — Conservation Science and Practice (Wiley), 2020 The Assessment Documents Roads as Invasive-Species Vectors Threatening 60 Percent of Listed Plants The USFWS Biological Assessment states at page 342: "Roads create favorable conditions for invasive plants by providing light gaps, dispersal corridors, and reduced competition. Vehicles and road maintenance equipment can spread invasive plant seeds, further contributing to their proliferation (Coffin et al. 2021)." At page 344 it quantifies the stakes: "Of the 134 plant taxa in this analysis 81 (60 percent) are threatened by invasive or non-native species." The record before the agency confirms the mechanism from the states' own experts: the North Carolina Wildlife Resources Commission (DEIS Vol. III, p. 210) — "IRAs often have less non-native invasive plants due to the lack of roads and other pathways generally associated with their spread and distribution" — and the Nevada Department of Wildlife (p. 187), documenting the loss of "nearly 71% of its core sagebrush habitats, driven in part by invasive annual grasses… Roads are known vectors for these invasives." The DEIS contains no quantified analysis connecting foreseeable new road mileage to invasive-species spread in the very areas whose comparative freedom from invasives its own record documents. I request the FEIS analyze invasive-species introduction risk by alternative, using the vector mechanism and the 60-percent threat figure its own assessment supplies. This land belongs to the public. Don't sign it away. Yours truly, CommentID: RLC-20260909-QLJO29