Comment Analysis · Docket FS-2025-0001

FS-2025-0001-524479

Opposes rescissionA2 moderateSubstance 15/24Owed an answerPosted October 1, 2026 On Regulations.gov

In short: The comment documents that the DEIS fails to project population-level impacts on elk and deer, does not apply its cited biodiversity fragmentation range to the 40.1 million acres of affected environment, ignores its own data on fire density in roadless areas, and fails to weigh the specific reliance interests of hunters and communities in the Pacific Northwest.

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, 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.
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
- “elk survival rates increased during a road closure”
- “elk avoid roads and select unroaded habitat”
- “roads built for oil extraction may have altered mule deer migration routes”
- “recovery of deer and moose populations in Alaska by preserving old-growth winter shelter”
Environmental Protection Biodiversity
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
- “look especially for raptors and owls when we hike”
- “projected biodiversity outcome is across those acres”
Forest Management Wildfire
- “the fewer roads there are, the fewer wildfires there are”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “reconcile rescission with that finding”
Economic Impact Fiscal
- “agency is already billions of dollars behind on maintaining existing roads”
- “leave taxpayers to cover the maintenance costs”
- “hand public resources to private industry”

What it names

National Forests: Olympic National Forest Wenatchee National Forest
Works cited: Sawyer et al. 2013

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 My husband and I have hunted together for ten years. The meat we eat is almost exclusively meat we harvested ourselves. Hunting is a huge part of our lives, and deer and elk populations in Washington and Oregon are already declining for a variety of reasons. Rescinding the Roadless Area Conservation Rule would accelerate that decline, undermining one of the biggest joys in our lives. I oppose this proposal. The agency's own record is clear about what roads do to elk. The DEIS cites the finding that "elk survival rates increased during a road closure and decreased when the gates were removed (Cole 1997), and that elk avoid roads and select unroaded habitat." That finding appears in the document; no population-level projection follows from it. The elk we pursue in Washington depend on unroaded cover and forage. Washington holds 139 inventoried roadless areas totaling 2,014,832 acres. Much of that is the kind of habitat that elk actually use. The agency owes hunters a projection of what rescission does to big game populations and to hunter opportunity, not a citation left dangling without consequence. Deer face the same problem. The DEIS cites Wyoming research finding roads built for oil extraction may have altered mule deer migration routes and increased their movement speed, with the agency citing Sawyer et al. 2013 for the proposition that unroaded security matters to deer. The agency's own Tribal record credits the rule's protection with the recovery of deer and moose populations in Alaska by preserving old-growth winter shelter. My husband and I pursue deer in places where that security still exists. The agency has not explained how losing that protection squares with its own citations on disrupted migration. I ask that the agency address this inconsistency directly. We also hike regularly in the Wenatchee National Forest and the Olympic National Forest. I took ornithology courses in college and look especially for raptors and owls when we hike. The DEIS cites the finding that "habitat fragmentation reduces biodiversity by 13 to 75 percent." That range appears and is then dropped. The affected environment is 40.1 million acres. The agency should apply its own cited fragmentation range to the full potentially affected environment and state plainly what the projected biodiversity outcome is across those acres. Stating a number and drawing no conclusion from it is not analysis. The proposal also justifies rescission in part on wildfire grounds. My husband and I own 20 acres of forestland, and so I make a point of keeping up to date on research into wildfire risks. The most recent research indicates the fewer roads there are, the fewer wildfires there are. The agency's 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." The agency must reconcile rescission with that finding. It must explain why the proposal departs from its own prior conclusions on fire occurrence, and it must account for what DEIS Table 21 shows about fire density on roaded versus roadless land. On fiscal grounds, the Roadless Rule is the responsible policy. The agency is already billions of dollars behind on maintaining existing roads. Rescission would hand public resources to private industry and leave taxpayers to cover the maintenance costs of whatever roads follow. That is a bad trade. Finally, the proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. This comment is exactly such an interest. My husband and I have organized our hunting, our food, and our recreational life around the continued protection the rule provides. Across the Pacific Northwest, 1,522 municipal water intakes sit in watersheds containing affected roadless areas, and communities have made decisions in reliance on that protection as well. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before it can lawfully change course. Sincerely, Ronda Larson Kramer Olympia, Washington