Comment Analysis · Docket FS-2025-0001

FS-2025-0001-537370

Opposes rescissionA1 strongSubstance 16/24Owed an answerPosted October 4, 2026 On Regulations.gov

In short: The comment establishes that the Draft EIS fails to apply its own quantitative fragmentation metrics from Appendix 5 to the comparative effects analysis of the three alternatives, leaving the conclusion unsupported by the agency's own data.

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
- “destruction and vandalization of these public lands”
- “clear cutting more old growth forests”
- “adverse effects on biodiversity by increasing habitat fragmentation”
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
Scientific Research Evidence
- “Fragmentation Metrics in Appendix 5 Never Applied to the Comparative Effects Conclusion”
- “computes a quantitative fragmentation baseline”
- “unsupported by the only measurements the Draft EIS made”
- “apply the Appendix 5 metrics to a projected post-rescission condition”
Forest Management Wildfire
- “old growth forests that cannot burn”
- “introduce 2nd growth vegetation that burns like gasoline”
- “road construction and reconstruction”
- “timber harvest”

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 placeAnalytical gapEvidenceAlternative

This is a sloppy job at covering up the fact that they are trying to roll back key legislation that has been the only thing stopping the destruction and vandalization of these public lands. Clear cutting more old growth forests that cannot burn will only introduce 2nd growth vegetation that burns like gasoline. Do not roll this back. You will be committing acts of destruction on innocent land. This land provides far too much for you to touch it. Fragmentation Metrics in Appendix 5 Never Applied to the Comparative Effects Conclusion Appendix 5 of the Draft EIS, "Biodiversity Analysis Supplemental Information" (pp. 320–333), computes a quantitative fragmentation baseline for the potentially affected environment: mean patch area, largest patch index, mean shape index, mean distance to nearest neighbor, edge density, and clumpiness index, broken out by region and by forest type group in Tables 56 and 57. Summarizing those tables, the Draft EIS states that "Most cover types were highly aggregated (CI), with none resembling a checkerboard pattern" (p. 321). None of those metrics appears anywhere else in the Draft EIS. "Largest patch index" occurs at pp. 320 and 324; "clumpiness" at p. 324; "nearest neighbor" at p. 321. Every occurrence falls inside Appendix 5. The metrics are absent from the biodiversity affected-environment discussion at pp. 141–142, from the road-construction effects discussion at pp. 149, 159, and 162, and from the conclusion at pp. 165–166. No projected or post-rescission value is given for any of them, under any alternative. I am not claiming the Draft EIS ignores fragmentation. It discusses fragmentation qualitatively at pp. 141–142 and ties it to species sensitivity, and it discusses fragmentation and edge effects from road construction at pp. 149, 159, and 162 with reference to named species including the cerulean warbler, elk, and the marbled murrelet. My concern is narrower, and I do not believe those sections answer it: the Draft EIS's conclusion is comparative, and it is unsupported by the only measurements the Draft EIS made. At pp. 165–166 the Draft EIS concludes that road construction, road reconstruction, and timber harvest "could potentially have long-term adverse effects on biodiversity by increasing habitat fragmentation, loss of connectivity, negative edge effects, and human disturbance"; that "[t]hese impacts would likely be more frequent and broader in scale under alternative 2"; that impacts under alternative 3 "would likely have a lesser effect on biodiversity than alternative 2"; and that impacts "would likely be the least under alternative 1." That is a ranking of the three alternatives by severity of fragmentation effect. It is stated entirely in words of degree — "more frequent," "broader in scale," "lesser," "least" — with no quantity attached to any of them, while the agency's own fragmentation measurements sit unused thirty pages later. The mechanism connecting the rescission to those measurements is the one the Draft EIS itself describes. Rescinding the 2001 Rule removes the prohibition on road construction and reconstruction in inventoried roadless areas under Alternative 2, and in a reduced subset of them under Alternative 3. New roads subdivide forest patches. Subdividing patches lowers mean patch area and largest patch index, raises edge density, and increases mean distance to nearest neighbor — these follow from the metrics' own definitions, and Appendix 5's table note says as much: "Largest patch index reflects habitat continuity and approaches 0 for highly fragmented landscapes." The link from that metric change to the biodiversity outcome the Draft EIS is ranking is supplied by Haddad et al. 2015, which the Draft EIS cites at pp. 141 and 149 for the findings that habitat fragmentation reduces biodiversity by 13 to 75 percent and that effects are greatest in the smallest and most isolated fragments and increase over time. The Draft EIS therefore holds, in its own record, both the baseline values and the published relationship between a change in those values and the effect it is comparing — and applies neither to the comparison. The scale objection does not reach this request. Appendix 5's metrics were computed by the agency at the scale of the affected environment as a whole, by region and forest type group, minus the area within 100 feet of existing roads. That is a rule-scale analysis, chosen by the agency, and a baseline computed at rule scale admits of a projection at rule scale. Nothing I am asking for requires knowing where individual future roads would be sited; it requires applying a bounded range of road-density or road-mileage assumptions to a baseline the agency has already built. Under 7 CFR 1b.7(f)(2)(iii) I request that the Forest Service supplement the biodiversity effects analysis to apply the Appendix 5 metrics to a projected post-rescission condition for each alternative — at minimum.