Comment Analysis · Docket FS-2025-0001

FS-2025-0001-533078

Opposes rescissionA2 moderateSubstance 13/24Owed an answerPosted October 4, 2026 On Regulations.gov

In short: The comment documents that the agency's Draft EIS contains internal contradictions regarding wildfire ignition rates and economic net benefits, and that the agency has failed to justify how the rescission of the 2001 Roadless Rule reconciles with its own findings on wildlife harm and legal authority under the Organic Act and MUSYA.

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
- “watch fish, deer, migrating birds, and other wildlife”
- “bird richness declines with road presence”
- “roads can alter deer migration routes”
- “preserving old-growth winter shelter”
Recreation Tourism Public Use
- “parks and natural areas I visit are already under strain”
- “hikers are injured, campers feel unsafe”
- “recreation losses estimated at $6.1 million annually”
- “natural spaces that restore my physical and mental health”
Forest Management Wildfire
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “fire-density data that undermines the proposal's stated reasoning”
- “agency relies on fuels management as part of its rationale”
Legal Regulatory Framework
- “challenge to the legal authority underlying the 2001 Rule”
- “prior federal appellate findings that the rule fell within authority”
- “state-by-state approaches can replace a national rule”
- “significant legal challenges”

What it names

National Forests: Chequamegon-Nicolet National Forest

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The parks and natural areas I visit are already under strain. Roads are overloaded, hikers are injured, campers feel unsafe, and pollution is increasing as staffing shortages limit management capacity. I moved an hour away from my workplace specifically to live near the kind of natural spaces that restore my physical and mental health. Because of that decision, I depend on the Chase Creek, Round Lake Study Area, Shelp Lake, Foursection, and Wheeler Lake and Shoe Lake island units within Wisconsin's Chequamegon-Nicolet National Forest. These inventoried roadless areas are among Wisconsin's 68,987 acres of protected roadless lands. They are where I watch fish, deer, migrating birds, and other wildlife, and where I photograph pelicans, waterfowl, squirrels, rabbits, and other species. On my most recent visit, I watched pelicans nesting with their mates. Rescinding the 2001 Roadless Area Conservation Rule threatens these experiences, and the agency has not justified that risk. Regarding wildfire, the agency relies on fuels management as part of its rationale, yet its own Draft Environmental Impact Statement states: "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 similarly reflects fire-density data that undermines the proposal's stated reasoning. The agency should explain why it is departing from its own findings and reconcile the rescission with the ignition data already in the record. The DEIS also cites research showing that bird richness declines with road presence in forested habitat and that road-noise experiments in roadless areas reduced bird abundance by more than 25%, with 31% of species avoiding the noise entirely. Those findings are directly relevant to the pelicans, waterfowl, egrets, and other birds I observe. The agency has not adequately explained how these documented harms are outweighed by any expected benefits of additional road construction. The same concern applies to deer. The agency cites research indicating that roads can alter deer migration routes and increase movement speed. The Tribal Summary Impact Statement credits the Roadless Rule with helping recover deer and moose populations by preserving old-growth winter shelter. If that protection is removed, the agency should clearly explain what will replace it. The economic case is also unconvincing. The agency's record states that timber affected by the rule accounts for less than 0.5% of total U.S. production and that oil and gas production from National Forest System lands accounts for about 0.4% of national production. Projected annual timber revenue gains of $5.2-$11.4 million are offset by recreation losses estimated at $6.1 million annually, while the net present value ranges from negative $92 million to positive $199 million. These figures do not establish a clear net benefit, particularly given an existing road maintenance backlog of roughly $6.9 billion. The agency should reconcile these numbers before proceeding. The proposal also assumes that state-by-state approaches can replace a national rule. Previous efforts to substitute state-specific management for nationwide protections were met with significant legal challenges. The agency should explain specifically how this proposal avoids those same deficiencies. Finally, the proposal's challenge to the legal authority underlying the 2001 Rule conflicts with prior federal appellate findings that the rule fell within authority granted by Congress under the Organic Act and MUSYA and did not create de facto wilderness. If the agency now takes a different position, it should clearly identify the legal basis for that change so the public and the courts can evaluate it. Wisconsin's 68,987 acres of inventoried roadless areas, along with the many communities, wildlife populations, and water resources that depend on them, deserve no less. **Sincerely,** Correy Montello, Wisconsin