Comment Analysis · Docket FS-2025-0001

FS-2025-0001-358014

Opposes rescissionA3 weakSubstance 8/24Owed an answerPosted September 12, 2026 On Regulations.gov

In short: The comment places on the record specific scientific evidence demonstrating that road construction in the Wheeler Lake Islands area of the Chequamegon-Nicolet National Forest increases wildfire ignition density and negatively impacts songbird nest survival, thereby opposing the rescission of the Roadless Rule.

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 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

Wildlife Habitat
- “roads fragment forests, which affects the ability of birds to successfully breed”
- “diversity of habitat and wildlife in this area is spectacular and too precious to lose”
- “distance to unpaved road was the model that most influenced daily nest survival”
Forest Management Wildfire
- “Roads also make wildfire more likely, not less”
- “wildfire ignition density within 50 meters of roads was nearly four times higher”
- “human-caused ignitions were concentrated near roads”
Scientific Research Evidence
- “I am familiar with the scientific findings”
- “A 2026 study covering 30 years of wildfire data”
- “Ecology and Evolution (PMC), 2014”

What it names

National Forests: Chequamegon-Nicolet National Forest
Roadless areas: 09184 - Wheeler Lake IslandsWhite Pine
Works cited: 10.1016/j.apgeog.2011.09.00410.1186/s42408-026-00450-2

The comment

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

Dear Chief Tom Schultz, I write in opposition to the proposed rescission of the Roadless Rule as a birder and wildlife conservationist, as well as a homeowner with beloved cabins in a National Forest in Northern Wisconsin. I am familiar with the scientific findings, much of it generated by the federal government, that indicate that roads fragment forests, which affects the ability of birds to successfully breed. Roads also make wildfire more likely, not less. The science points against rescission of the Roadless Rule. The region surrounding Wheeler Lake was heavily logged during the late 19th and early 20th centuries. Initial harvests focused on virgin white pine from approximately 1835 through the 1860s, followed by hardwoods such as maple and oak. The Holt Lumber Company operated a specific line known as the Wheeler Spur, which ran a few miles south from Townsend toward the lake region. By the 1920s, the land was described as "over-cut, burned-over, and farmed-out." Much of the land became tax-delinquent and was abandoned by owners. The Roadless Rule has protected the Wheeler Lake Islands area from logging and logging roads for 25 years. The diversity of habitat and wildlife in this area is spectacular and too precious to lose. t's taken a hundred years for this area to recover from heavy logging. It’s now a beautiful area beloved by many. Let’s not ruin it again. If logging roads cut through this area the probability of wildfires will increase, not decrease. Roads are where most wildfires start. A 2026 study covering 30 years of wildfire data across the entire National Forest System found that wildfire ignition density within 50 meters of roads was nearly four times higher than the average for non-wilderness, non-roadless forest lands. Wilderness areas and Inventoried Roadless Areas had the lowest ignition densities of any category studied (Aplet et al. 2026). — Aplet et al., 2026 (https://doi.org/10.1186/s42408-026-00450-2) Most ignitions near roads are human-caused. The same study found that human-caused ignitions were concentrated near roads, near the wildland-urban interface, and in high-road-density areas. Lightning-caused ignitions, by contrast, were concentrated away from roads and in lower-density areas. The further from a road, the fewer human-caused fires (Narayanaraj & Wimberly 2012; Aplet et al. 2026). — Wimberly, 2012 (https://doi.org/10.1016/j.apgeog.2011.09.004); Aplet et al., 2026 (https://doi.org/10.1186/s42408-026-00450-2) Regarding the 09184 - Wheeler Lake Islands in the Chequamegon-Nicolet National Forest, Wisconsin: "From a sample of 463 nests of 17 songbird species, we evaluated how landscape features (distance to forest edge, unpaved roads, and power lines) influenced daily nest survival. For all nesting species combined, distance to unpaved road was the model that most influenced daily nest survival. Numerous nest predators, including brown-headed cowbirds, mammalian mesopredators, and snakes, have been shown to preferentially occupy habitat edge over interior. Rat snakes were frequently associated with road edges, indicating that not all edges are functionally similar." — Ecology and Evolution (PMC), 2014 “The Roadless Rule does not replace forest plans. It supplements them — adding a layer of protection against road construction and most commercial timber harvest across all 44.5 million acres of inventoried roadless area, regardless of what the underlying forest plan would otherwise permit (USDA Forest Service 2001)” This comment is against rescission. Thank you, Margaret Poethig