Comment Analysis · Docket FS-2025-0001

FS-2025-0001-391757

Opposes rescissionA3 weakSubstance 10/24Owed an answerPosted September 14, 2026 On Regulations.gov

In short: The comment places on the record specific scientific data from the NCSSF Project C10.4 report and the DEIS regarding the loss of old-growth forests, the impact of roads on wildlife and sediment, and requests that the agency quantify these losses and explain how rescission is consistent with its own findings.

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.

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

Environmental Protection Biodiversity
- “loss of LSOG and biological legacies such as snags and coarse woody debris”
- “all remaining old growth and late successional forest on public lands in the region requires protection”
- “bird richness declines with road presence in forested habitat”
Wildlife Habitat
- “concerned about species still in recovery here, particularly gray wolves and martens”
- “marten populations decline when forest cover thins”
- “road-noise experiments in a roadless area cut bird abundance by over a quarter”
Water Quality Quantity
- “Water quality is particularly important for people and for fauna in the Upper Peninsula”
- “Roadbuilding increases sediment flow into tributary streams”
- “sedimentation from harvest can promote excessive substrate movement, causing egg and juvenile mortality”
Recreation Tourism Public Use
- “I frequently walk, bird, botanize, and watch wildlife in this area”
- “important for local recreation (the North Country Trail is contiguous to it)”

What it names

National Forests: Ottawa National Forest
Roadless areas: Norwich Plains Revised Roadless AreaWhite Pine

Attachments

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

Own letter
Own letter

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 I oppose the rescission of the 2001 Roadless Area Conservation Rule and ask that the agency respond to each of the following points in the record. As a retired forest ecologist and faculty member who spent much of her career working on old growth and late successional forests (LSOG), I am particularly concerned about loss of LSOG and biological legacies such as snags and coarse woody debris. In 2006, I led the National Commission on Science for Sustainable Forestry workshop on old growth in the Upper Midwest, which brought together 32 old-growth researchers. Our report was published as NCSSF Project C10.4: Great Lakes Old Growth Workshop, June 2006. We found that less than 1% of the pre-cutover era old growth remains in the Upper Midwest, with particularly sharp declines in hemlock, yellow birch, and white pine, and that fragmentation, road building, and invasive species rank among the major threats. We further found that all remaining old growth and late successional forest on public lands in the region requires protection. I ask that the agency identify what measures, short of retaining the rule, will protect remaining LSOG forests in the Upper Midwest and across the nation. The National Commission on Science for Sustainable Forestry workshops also found that retention of biological legacies such as snags and coarse woody debris on the forest floor are important for reducing fire risk and protecting soil biodiversity. I ask that the agency quantify the expected loss of snags, coarse woody debris, and other biological legacies if the roadless rule is rescinded and clarify plans to retain these biological legacies for ecological resilience. Our local roadless area on the Ottawa National Forest is the Norwich Plains Revised Roadless Area. I frequently walk, bird, botanize, and watch wildlife in this area, and it is precious to me. At 4,360 acres, it is small but still important for local recreation (the North Country Trail is contiguous to it) and for the Ontanagon River watershed. I am concerned about species still in recovery here, particularly gray wolves and martens. The DEIS cites the finding that wide-ranging mammals "have suffered habitat loss and the extirpation or fragmentation of their populations," and documents that marten populations decline when forest cover thins, that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. I ask that the agency explain, on the record, how rescission is consistent with its own documented findings on habitat fragmentation and road-induced wildlife displacement. Water quality is particularly important for people and for fauna in the Upper Peninsula. Roadbuilding increases sediment flow into tributary streams, which can degrade spawning habitat for trout and other aquatic fauna. As the agency's analysis notes, roads and their skid trails and landings contribute up to 90 percent of the sediment from a timber sale, and sedimentation from harvest can promote excessive substrate movement, causing egg and juvenile mortality and reduced suitable habitat for fish. The agency must identify what measures, short of maintaining the rule, would prevent sediment loading in these watersheds at the level its own data describe. Sincerely, Dr. Nancy Langston, Distinguished Professor Emerita, Michigan Technological University Chassell MI 49916