Comment Analysis · Docket FS-2025-0001

FS-2025-0001-460048

Opposes rescissionA2 moderateSubstance 10/24Owed an answerPosted September 21, 2026 On Regulations.gov

In short: The comment places on the record specific economic data showing a negative net present value for the proposed action, cites DEIS findings on increased road maintenance costs and sedimentation impacts on water quality, and documents the commenter's personal use of the roadless lands for 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

A2 moderate: Hard to dismiss — it shows cause and effect.

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.
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.

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.
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
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
- “bird richness declines with road presence”
- “Marten disappear when forest cover thins; wolverine avoid roads”
- “grizzly bear have suffered habitat loss and the extirpation or fragmentation of their populations”
Water Quality Quantity
- “24 million people use water that originates inside the roadless areas”
- “skid roads, trails and log landings... are the main cause of soil erosion”
- “contribute up to 90 percent of the sediment generated by timber sale activity”
- “costs to health and increased costs of water cleaning”
Recreation Tourism Public Use
- “thousands go for quiet country, for solace, for fishing and for hunting”
- “no-action alternative maintains the most opportunities for quiet, remote and self-reliant recreation”
- “rescission alternative has the greatest potential for negative effects to scenery”
- “lost recreation benefit”
Economic Impact Fiscal
- “net present value that runs to negative $92 million”
- “road mileage, deferred maintenance and management costs are likely to increase”
- “maximum projected timber revenue is $5.2 to 11.4 million a year”
- “Road appropriations fell from $234 million in 2004 to $73 million in 2024”

What it names

Works cited: Haddad et al. 2015Kroeger et al. 2022

The comment

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

I have backpacked, photographed in these roadless lands. This regulation proposes to take away, destroy, another magnificent aspect of our country and an immense resource for short term profit. Shame. Specifically, you address roads. Road appropriations fell from $234 million in 2004 to $73 million in 2024, against a $6.9 billion deferred maintenance backlog. The supplemental funding is expiring. Maximum projected timber revenue is $5.2 to 11.4 million a year, against up to $6.1 million a year in lost recreation benefit by its own figures, and the agency’s own cost-benefit analysis states a net present value that runs to negative $92 million. The DEIS states outright that road mileage, deferred maintenance and management costs are likely to increase. (DEIS economics and infrastructure analysis; USDA Cost Benefit Analysis, p. 29.) In short, there aren’t the funds for the current roads and your budget continues to shrink. Roads and timber: Roads and timber harvesting will create forest fragmentation. The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent, 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. Marten disappear when forest cover thins; wolverine avoid roads used by winter machines. On big animals, its own words: wide-ranging mammals like the grizzly bear “have suffered habitat loss and the extirpation or fragmentation of their populations.” (DEIS wildlife analysis; USFWS draft Biological Assessment; Haddad et al. 2015; McClure et al. 2013.) In addition, the DEIS cites the findings 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. (DEIS; Kroeger et al. 2022; McClure et al. 2013; Ware et al.) Wildfire risk: Roads result in greater likelihood of fires. The majority of forest fires start within ten miles of roads. This will increase the number of forest fires while at the same time decreasing funding that would enable staff to fight them. Madness. Recreation: Absolutely. This is where thousands go for quiet country, for solace, for fishing and for hunting. The DEIS concedes the no-action alternative maintains the most opportunities for quiet, remote and self-reliant recreation, and that under rescission the settings could shift toward more developed conditions. In the DEIS’s own comparison, the rescission alternative “has the greatest potential for negative effects to scenery.” The agency understands the visual consequence and is choosing to accept it. No room for beauty, it seems, in the current administration. Mineral and Energy: No, coal has no future in this country, neither has oil. This proposed change is being built on an energy mirage, and is sacrificing short term destruction of long-term health. Water: Not mentioned! Approximately 24 million people use water that originates inside the roadless areas this action reaches, through more than 7,000 municipal water intakes. Right now that water is clean: less than 12 percent of the watersheds containing these areas have impaired streams. By the agency’s own analysis, the skid roads, trails and log landings that come with timber harvest are the main cause of soil erosion and can contribute up to 90 percent of the sediment generated by timber sale activity. (DEIS Table 35; Forests to Faucets 2.0 / EPA SDWIS.) The costs to health and increased costs of water cleaning have, I assume, not been addressed. Perhaps this administration doesn’t drink water and cartes little for those on public water supplies?