Comment Analysis · Docket FS-2025-0001

FS-2025-0001-534149

Opposes rescissionA1 strongSubstance 14/24Owed an answerPosted October 4, 2026 On Regulations.gov

In short: The comment establishes that the Draft EIS's claim of habitat for "more than 300" species is factually unreconcilable with the Draft Biological Assessment's methodology and lacks specific counts, dates, and cross-references, while failing to integrate the cited Dietz et al. (2021) study on roadless area importance for vulnerable species into its effects analysis.

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

Environmental Protection Biodiversity
- “Biodiversity is necessary for life on earth to continue”
- “Repealing the roadless rule would devastate these ecosystems”
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
- “308 — 57 percent — have at least some suitable habitat in inventoried roadless areas”
Scientific Research Evidence
- “Species Count Not Reconcilable to the Biological Assessment”
- “The Draft EIS states at p. 141... that '[t]he most recent USFWS and NMFS data indicate that the potentially affected environment of inventoried roadless areas provides habitat for more than 300 threatened, endangered, and proposed species'”
- “A synthesis of fragmentation experiments spanning five continents and 35 years demonstrates that habitat fragmentation reduces biodiversity”
- “Matthew S. Dietz, Kevin Barnett, R. Travis Belote and Gregory H. Aplet, 'The Importance of US National Forest Roadless Areas for Vulnerable Wildlife Species'”
Legal Regulatory Framework
- “The Final EIS should make a factual correction under 7 CFR 1b.7(f)(2)(v)”
- “7 CFR 1b.7(f)(3) directs that the Final EIS cite where it was made”
- “The Biological Assessment reports counts only by taxonomic group”
- “occurrence databases 'do not differentiate between DPSes of vertebrate species listed under the ESA'”
Climate Carbon Storage
- “We are already hurtling towards the worst effects of the climate crisis”
- “Why are we trying to speed up the progress?”
- “Is our governments main goal to kill the whole world even faster?”

What it names

Law cited: 7 CFR 1b
Works cited: Haddad et al. 2015

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeEA analysisAnalytical gapEvidenceLegal

Biodiversity is necessary for life on earth to continue. In a beginners ecology class one of the first and arguably most important things you learn is that the more diverse an ecosystem is, the better chance it has of surviving changes. Repealing the roadless rule would devastate these ecosystems forever change the biodiversity of the land. We are already hurtling towards the worst effects of the climate crisis. Why are we trying to speed up the progress? Is our governments main goal to kill the whole world even faster? Species Count Not Reconcilable to the Biological Assessment; Record Study on Species Representation Not Engaged The Draft EIS states at p. 141, under Assumptions Common to All Alternatives → Potentially Affected Environment → Habitat, that "[t]he most recent USFWS and NMFS data indicate that the potentially affected environment of inventoried roadless areas provides habitat for more than 300 threatened, endangered, and proposed species," and repeats the figure at p. 168. Neither statement gives the exact count, the date the data reflect, or a cross-reference to the document that produced it. The Draft Biological Assessment for USFWS species does disclose a method, and this comment does not suggest otherwise: IRA boundary shapefiles by administrative unit were imported into IPaC to compile the FWS list, NMFS species were compiled from existing consultation documents, both lists were vetted by regional Forest Service staff to remove species that do not occur on National Forest System lands, the lists were sent to the Services for review in September and October 2025, and occurrence data were drawn from GBIF and the Natural Resource Manager (Draft BA, "Species Lists" and "Data Collection and Use," p. 25). The defect is that the Draft EIS's figure cannot be reconciled to that method. The Biological Assessment reports counts only by taxonomic group — for example, "[t]he potential species list from IPaC contained 30 listed or proposed bird species on relevant Forest Service units," of which four were removed and "[t]he 26 potentially present species are organized below" (Draft BA p. 161) — and states no total. The Biological Assessment also warns that its occurrence databases "do not differentiate between DPSes of vertebrate species listed under the ESA, which causes potential inflation of exposure to these entities" (p. 25), so whether the Draft EIS's total counts distinct population segments separately changes the number materially. A reader cannot determine what "more than 300" counts, on what date, or against which vetted list. The Final EIS should make a factual correction under 7 CFR 1b.7(f)(2)(v): state the exact number of threatened, endangered, and proposed species in the potentially affected environment, state the date the species lists reflect, state whether distinct population segments are counted separately, and cross-reference the Biological Assessment's Species Lists section at each point the figure is used. This is a correction the agency can make from documents it already holds, and 7 CFR 1b.7(f)(3) directs that the Final EIS cite where it was made. Second, the figure does no analytical work as written. It appears twice in "Potentially Affected Environment" as descriptive background and is never carried into an effects conclusion — even though the Draft EIS concedes the operative mechanism on the same page, stating at p. 141 that "[a] synthesis of fragmentation experiments spanning five continents and 35 years demonstrates that habitat fragmentation reduces biodiversity by 13 to 75 percent (Haddad et al. 2015)" and that "[e]ffects tend to be greatest in the smallest and most isolated fragments, increasing over time." The record already contains the study that gives the species count its consequence. Matthew S. Dietz, Kevin Barnett, R. Travis Belote and Gregory H. Aplet, "The Importance of US National Forest Roadless Areas for Vulnerable Wildlife Species," 32 Global Ecology and Conservation e01943, 1-12 (2021), appears in the Draft EIS's own reference list, is cited in full in Volume III at p. 37 (n. 201), is set out at length in Volume III at pp. 38-39 in the comment letter of the Attorneys General of Washington, California, Arizona, Massachusetts, Minnesota, New Mexico, Oregon and Vermont, and is cited again in the joint Tribal letter at Volume III p. 498. As that letter states the finding: of 537 terrestrial vertebrate species of conservation concern, 308 — 57 percent — have at least some suitable habitat in inventoried roadless areas, "even though inventoried roadless areas only cover 2% of the area of the contiguous United States"; every inventoried roadless area contains suitable habitat for at least two such species; and 81 percent of inventoried roadless area land is suitable habitat. Please show me that the people voice is more valuable than money.