Comment Analysis · Docket FS-2025-0001

FS-2025-0001-495336

Opposes rescissionA1 strongSubstance 17/24Owed an answerPosted September 28, 2026 On Regulations.gov

In short: The comment documents that the DEIS fails to quantify sediment delivery to municipal intakes, reconcile the contradiction between road maintenance backlogs and new road construction, or explain how forest plans provide equivalent protection to 36 CFR 294.12/294.13, while citing specific data on bird abundance decline and fire density on roaded lands.

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

Wildlife Habitat
- “photograph native birds and the natural landscape”
- “bird richness declines with road presence”
- “31 percent of species avoiding the noise entirely”
- “natural habitat can survive”
Water Quality Quantity
- “Wildlife depends on clean water”
- “24 million people use water originating within the potentially affected roadless areas”
- “skid roads... are the main cause of soil erosion”
- “quantify projected sediment delivery to those intakes”
Forest Management Wildfire
- “Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “DEIS Table 21 reports higher fire density on roaded land”
Legal Regulatory Framework
- “protections currently found in 36 CFR 294.12 and 294.13”
- “The claim that other plans fill the gap is asserted, not demonstrated”
- “reconcile the rescission with the ignition data its own analysis contains”

What it names

National Forests: Allegheny National Forest
Roadless areas: Clarion River
Law cited: 36 CFR 294.12

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequest

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Clarion River watershed already carries the weight of overdevelopment. I paddle its rivers and streams, and I photograph native birds and the natural landscape there. What I want from the Forest Service is a straight answer about why it proposes to make things worse. The Clarion River roadless area covers 3,821 acres inside the Allegheny National Forest in Pennsylvania. Pennsylvania holds 7 inventoried roadless areas totaling 24,866 acres. These are not vast reserves. They are what remains. The Clarion River area is already under pressure, and it needs protection so that its natural habitat can survive. Opening it to roads works against that plainly. Wildlife depends on clean water. The native birds I photograph in forested habitat depend on intact, quiet, unroaded land as well. The DEIS cites 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. The rescission proposal does not address what happens to these populations when roads come in. The agency should explain what its analysis shows for bird communities in areas like Clarion River if the rule is removed. On the question of water, the agency's own document states: "Approximately 24 million people use water originating within the potentially affected roadless areas, through more than 7,000 municipal intakes, and less than 12 percent of these watersheds are currently impaired." Across the Eastern region, which includes Pennsylvania, 286 municipal water intakes sit in watersheds containing affected roadless areas. That low impairment rate is a reason to continue protection, not to end it. The DEIS also states that skid roads, trails, log landings and similar disturbances within timber sale areas are the main cause of soil erosion and "can contribute up to 90 percent of the sediment generated by timber sale activity." The document presents that number and then moves on, without projecting how much sediment would actually reach the intakes downstream. I ask that the agency quantify projected sediment delivery to those intakes before finalizing any rescission. The DEIS argues that forest plans will protect municipal drinking water in the absence of the Roadless Rule. That argument is not supported by specifics. The agency should identify, forest by forest, which existing plan provisions are equivalent to the protections currently found in 36 CFR 294.12 and 294.13 for municipal watersheds. The claim that other plans fill the gap is asserted, not demonstrated. The agency also identifies its own road maintenance backlog as a water quality problem and then proposes to add road mileage anyway. Its own text states: "Lack of maintenance commonly has detrimental effects on water quality. Insufficient maintenance funding is a key reason for the lack of adequate road maintenance." How does adding roads to an underfunded maintenance system improve water quality for the birds, the wildlife, and the people downstream? The agency must reconcile that contradiction before this proceeding closes. On fire, the agency justifies rescission partly on fuels and wildfire management grounds. Its own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." DEIS Table 21 reports higher fire density on roaded land than inside affected roadless areas. The proposal should explain why it departs from these findings and reconcile the rescission with the ignition data its own analysis contains. The Clarion River area is already overdeveloped. These acres do not need more roads. They need the protection the 2001 rule provides. The agency should answer these questions in the record before it acts. Sincerely, Kiki Kleiman Los Angeles, CA