Comment Analysis · Docket FS-2025-0001

FS-2025-0001-353357

Opposes rescissionA3 weakSubstance 12/24Owed an answerPosted September 12, 2026 On Regulations.gov

In short: The comment establishes that the Draft EIS fails to analyze the specific finding from Olden et al. (2026) regarding the Roadless Rule's role as the primary protection for over 100,000 kilometers of rivers and requests that the Final EIS quantify the loss of this protection under Alternative 2.

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

Water Quality Quantity
- “primary protection mechanism for more than 100,000 kilometers... of rivers”
- “watersheds influenced by roadless areas provide public drinking water to an estimated 25 million Americans”
- “Protecting headwaters on public land helps protect water quality”
Recreation Tourism Public Use
- “countless hours hiking, mountain biking, backpacking, adventure racing”
- “quiet, clean streams... and places where people can travel under their own power”
- “supporting recreation and freshwater biodiversity”
Environmental Protection Biodiversity
- “wildlife habitat, connected forest”
- “freshwater biodiversity”
- “removing a durable national safeguard and replacing it with case-by-case decisions that may allow new roads, fragmentation”
Scientific Research Evidence
- “Recent peer-reviewed science shows why this matters”
- “Olden et al. (2026), in PLOS Water”
- “The Final EIS should directly analyze how many river miles would lose their primary protection”

What it names

National Forests: Mark Twain National Forest
Roadless areas: Anderson MountainBig CreekPiney CreekSpring Creek
Works cited: 10.1371/journal.pwat.0000538

Attachments

1 file. Counts as 1 — Counts as one: The attachments enclose no one else's submissions; the comment counts as one.

Own letter

The comment

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

I strongly oppose Alternative 2, the full rescission of the 2001 Roadless Area Conservation Rule, and urge the Forest Service to retain the Rule under Alternative 1. This issue is personal to me. I have spent 47 years as a Missourian and Coloradoan, and countless hours hiking, mountain biking, backpacking, adventure racing, hunting alongside family, and respecting public lands. In 2001, the same year the Roadless Rule was adopted, I took my first overnight backpacking trip in Devil’s Backbone Wilderness in Mark Twain National Forest. I have also adventure raced at Piney Creek. I was born in Cape Girardeau, and much of my family still lives, hunts, and farms in southeast Missouri around Cape Girardeau and Poplar Bluff. I understand that Devil’s Backbone and Piney Creek are designated Wilderness and have protections independent of the Roadless Rule. I mention them because they taught me what intact, undeveloped Ozark landscapes mean: quiet, clean streams, wildlife habitat, connected forest, and places where people can travel under their own power without an expanding road network. Other inventoried roadless areas in Mark Twain National Forest, including Anderson Mountain, Big Creek, Irish, Spring Creek, and Swan Creek, do not all have the same permanent Wilderness protection and would be more directly affected by rescission. Recent peer-reviewed science shows why this matters. Olden et al. (2026), in PLOS Water, found that after accounting for other regulatory and conservation protections, inventoried roadless areas are the primary protection mechanism for more than 100,000 kilometers—about 62,000 miles—of rivers in the contiguous United States. The same study found that watersheds influenced by roadless areas provide public drinking water to an estimated 25 million Americans while supporting recreation and freshwater biodiversity. Study: Julian D. Olden et al., “Assessing the value of the U.S. Roadless Rule for people and nature,” PLOS Water 5(7): e0000538 (2026). https://doi.org/10.1371/journal.pwat.0000538 That finding is especially important to people in rural Missouri. Forests, farms, hunting, streams, wildlife, and downstream communities are part of the same landscape. Protecting headwaters on public land helps protect water quality, habitat, recreation, and the people who live and work downstream. The Draft EIS discusses water resources and road-related impacts generally, but it does not appear to address Olden et al.’s specific finding that the Roadless Rule remains the primary protection for tens of thousands of miles of rivers even after other protections are considered. The Final EIS should directly analyze how many river miles would lose their primary protection under Alternative 2 and what that would mean for water quality, aquatic habitat, recreation, and downstream communities. I am not opposed to responsible forest management, wildfire response, public safety work, or habitat restoration. The existing Rule already includes exceptions. What I oppose is removing a durable national safeguard and replacing it with case-by-case decisions that may allow new roads, fragmentation, and development in places that have remained intact for a generation. In 2001, I learned what a roadless landscape meant on my first overnight backpacking trip in Devil’s Backbone. Twenty-five years later, I am asking the Forest Service not to abandon the rule adopted that same year. Please reject Alternative 2 and retain the 2001 Roadless Area Conservation Rule.