Comment Analysis · Docket FS-2025-0001

FS-2025-0001-354788

Opposes rescissionA1 strongSubstance 17/24Owed an answerPosted September 12, 2026 On Regulations.gov

In short: The comment documents that the agency's analysis fails to explain the departure from the 2001 finding that roadless protections benefit listed species and concedes unquantified recreation losses, while citing scientific evidence that road networks facilitate invasive species spread.

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

A1 strong: Must be answered — it names the law.

Owed an answer on Analytical gap, Evidence, Legal.

Standard dismissals it defeats

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.
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.
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.

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.
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.

Topics

Recreation Tourism Public Use
- “bulldozed roadbeds would ruin those experiences”
- “loss of conservation values”
- “negatively impact tourism and outdoor recreation”
- “forgone recreation benefits”
Environmental Protection Biodiversity
- “Road networks cause habitat fragmentation”
- “spread of invasive alien plants”
- “beneficially affect threatened, endangered, and proposed species”
- “loss of conservation values”
Legal Regulatory Framework
- “must show that there are good reasons for the new policy”
- “NEPA requires an agency to analyze”
- “factual basis for departing from it”
- “concurred-in finding that the prohibitions... benefit listed species”

What it names

National Forests: Talladega National Forest
Roadless areas: Cheaha B
Law cited: 463 U.S. 29 490 U.S. 332 556 U.S. 502 795 F.3d 956
Works cited: 10.1111/ddi.70002

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 gapEvidenceLegal

To the Department of Agriculture: As someone who has used roadless national forest in multiple regions and in multiple seasons, I am submitting these comments to establish that the public value the 2001 Rule has protected is observable, documented, and not recoverable once road infrastructure has been authorized and constructed within currently protected areas. I remember walking with my husband on some of our very first dates in Cheaha park and now we love to take our children. Sitting at the top of the lookout always felt like stepping back in time and getting away from all of the stress of modern life. My family loves to hike the area and bulldozed roadbeds would ruin those experiences. Regarding the Cheaha B in the Talladega National Forest, Alabama: “In 2001 the Agency Found These Prohibitions Benefited Listed Species; the Rescission Never Engages Its Own Prior Finding Both Draft Biological Assessments open with the same acknowledgment (USFWS BA p. 10; NMFS BA p. 7): "In the promulgation of the 2001 Roadless Rule, the Forest Service found that the Rule's prohibitions on road construction and timber harvest were not likely to adversely affect threatened or endangered species or adversely modify designated or critical habitat; were not likely to jeopardize proposed species or adversely modify proposed critical habitat; and may beneficially affect threatened, endangered, and proposed species and critical habitat… The Services concurred with the determination." The agency thus stands on a concurred-in finding that the prohibitions it now proposes to delete benefit listed species — and the current assessments anticipate widespread adverse effects from deleting them. When an agency reverses course, it "must show that there are good reasons for the new policy," FCC v. Fox Television Stations, 556 U.S. 502, 515 (2009), and where the prior policy rested on factual findings, it may not simply disregard them — the principle applied to this very rule's Tongass history in Organized Village of Kake v. USDA, 795 F.3d 956, 966–68 (9th Cir. 2015) (en banc). Neither the DEIS nor the assessments explain what changed in the biology. I request the FEIS directly address the 2001 beneficial-effect finding and state the factual basis for departing from it.” “Road networks cause habitat fragmentation and create edges with high resource availability that can act as important channels for the spread of invasive alien plants in various habitats, including nature reserves. In natural secondary forests, species richness, density and the proportion of invasive species significantly decreased with distance from the road; natural secondary forests contained only 5 invasive versus 67 native species, yet invasive species were concentrated near road edges. Human-induced changes to environmental conditions along roadsides increase soil moisture, soil disturbance, soil nutrients, exposure to sun and soil temperature, all of which are factors known to promote plant invasions. — Diversity and Distributions / Wiley Online Library, 2025 (https://doi.org/10.1111/ddi.70002)” The Analysis Concedes Recreation Losses Are "Most Likely," Quantifies Them as Costs, and Cannot Even Count the Visitors at Risk The Economic Analysis concedes at page 25: "In the long-term, any changes in aggregate economic benefit to recreationists that occur under the proposed rule are most likely to be losses because timber harvest and road construction is anticipated to negatively change the recreation settings and opportunities for trail-based and dispersed area recreation within potentially affected IRAs… The magnitude of those losses is unknown." At page 30 it books real costs: "Costs include forgone recreation benefits (minimum of $6.1 million annually) and forgone passive use values ($5.3 to $11.5 million annually) from increases in timber harvest in roadless areas." At page 28 it concedes the mechanism: "The construction and use of roads can degrade the unique characteristics of roadless areas… leading to loss of conservation values… These impacts from road development could negatively impact tourism and outdoor recreation." And at page 16 it admits it cannot even measure the exposure: "The number of recreation visits to IRAs is unknown and, thus, the recreation visitor spending in local communities associated with IRA recreation cannot be directly quantified." Certain-direction losses of unknown and unmeasured magnitude are precisely what NEPA requires an agency to analyze rather than wave through. Robertson, 490 U.S. 332; State Farm, 463 U.S. 29. I request the FEIS quantify recreation exposure (visitation and spending) in affected IRAs before relying on an analysis that concedes losses it cannot measure. When this process is over, I want the Roadless Rule still standing. I'm filing this comment to help make that happen. Most respectfully, CommentID: RLC-20260909-GQZC8R