Comment Analysis · Docket FS-2025-0001

FS-2025-0001-437944

Opposes rescissionA0 noneSubstance 8/24Posted September 17, 2026 On Regulations.gov

In short: The comment establishes the specific local significance of the Norwich Plains Roadless Area in the Upper Peninsula of Michigan, documenting its proximity to the commenter, its ecological value, and its role in regional recreation.

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

A0 none: Counted, not answered.

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.
Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
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.
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.

Topics

Recreation Tourism Public Use
- “lifelong outdoors person”
- “backpacking trip”
- “quiet and solitude”
- “wilderness enjoyment by visitors”
Environmental Protection Biodiversity
- “monumental threat to our wilderness areas”
- “protecting habitat and ecological diversity”
- “disproportionately large share of forest biodiversity”
- “intact habitats for wolves”
Water Quality Quantity
- “headwaters of several relatively undisturbed trout streams”
- “water quality of streams and lakes”
- “increase sediment in streams & lakes”
- “impacts on wildlife, bird, insect, and plant diversity”
Wildlife Habitat
- “wildlife habitat”
- “trout fisheries”
- “intact habitats for wolves”
- “introduce non-native plant & insect species”

What it names

National Forests: Bridger-Teton National Forest Ottawa National Forest

The comment

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

My name is Joan Schumaker Chadde. I live in the Upper Peninsula of Michigan. I have a B.S. in Natural Resources from the University of Michigan and an M.S. in Water Resources from the University of Wyoming. I am a lifelong outdoors person. My first backpacking trip was when I was 18, and I'll be backpacking this weekend on Isle Royale National Park at the age of 71. I still have a decade of backpacking ahead of me! During the time I lived in Wyoming, I backpacked & hiked in the Bridger-Teton National Forest and the Medicine Bow National Forest. In Montana, I hiked and backpacked in the Bridger-Teton, Lolo, Bitterroot, Flathead, and Gallatin National Forests. The nearest national forest to me now is the Ottawa National Forest. I enjoy hiking in the 4,360 acre Norwich Plains Roadless Area -- the only Roadless Area in the Ottawa National Forest and one of the largest intact tracts of public land in Michigan. Lying in the middle of Ontonagon County in the western Upper Peninsula, the Norwich Plains are the headwaters of several relatively undisturbed trout streams. The Norwich Plains Roadless area is just a 90-mile drive from my house, the next closest roadless area would be hundreds of miles away. I live near Houghton, home of Michigan Technological University. Students come not only for engineering and forestry degrees, but also for the amazing recreation in the Ottawa National Forest. The Norwich Plains Roadless Area has not been intensively logged since the 1980s, and it is home to mature second growth forest as well as stands of old growth aspen and traces of the spruce-fir-cedar forest that dominated the area before the logging of the 19th century. In addition to these ecological resources, the Norwich Plains are also directly adjacent to the North Country National Scenic Trail and offer outstanding views of Norwich Bluff, one of my favorite places to visit in the Fall. I am also a frequent visitor to many roadless areas in the Bitterroot & Lolo National Forests in MT, and in the Bridger-Teton N.F. The Roadless Rule Rescission is a monumental threat to our wilderness areas, the water quality of streams and lakes, trout fisheries, and wildlife habitat. Increasing roads in national forests will increase sediment in streams & lakes, introduce non-native plant & insect species, increase noise & traffic, and greatly diminish opportunities for quiet and solitude. A lot of effort went into gathering public comments 25 years ago when the Roadless Rule was first established. There is absolutely no reason to undo the tremendous progress made in protecting habitat and ecological diversity. Roadless areas contain a disproportionately large share of forest biodiversity. The Norwich Plains roadless area is a highlight of the North Country Trail in Michigan. I request the Forest Service to consider how future road construction and associated infrastructure could introduce new invasive species into currently intact forest landscapes. This includes not only disturbance directly along roads, but disturbance associated with facilities, work areas, vehicles, and future development. The Forest Service needs to consider the cumulative effects of introducing road disturbance & timber harvesting into landscapes that currently experience little or none. Assessing cumulative impacts of road construction and timber harvesting in a watershed was required when I worked for the Montana Dept of Natural Resources & Conservation 1986-1995, as well as, potential impacts on wildlife, bird, insect, and plant diversity, as well as, wilderness enjoyment by visitors. This should still be a requirement now. The results of the Forest Service's assessment of impacts needs to be shared with the public. Given the impossibility of creating new Roadless Areas, I strongly ask the Forest Service to retain the Roadless Area Conservation Rule and to demonstrate that recreation, ecological diversity, and intact habitats for wolves are fully considered in its decision-making. Thank you for the opportunity to comment and I strongly request that you maintain the Roadless Rule intact as it is now. It works!