Comment Analysis · Docket FS-2025-0001

FS-2025-0001-542648

Opposes rescissionA2 moderateSubstance 10/24Owed an answerPosted October 4, 2026 On Regulations.gov

In short: The comment establishes that the DEIS and draft biological assessment identify specific adverse impacts on bird abundance, biodiversity, elk populations, water quality, and carbon storage, as well as likely adverse effects on 327 ESA-listed species, but fail to provide population-level projections, carbon quantification, or mitigation strategies for the 40.1 million acres of affected roadless areas.

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.

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
- “bird richness declines with road presence”
- “habitat fragmentation reduces biodiversity”
- “elk survival rates increased during a road closure”
- “adversely affect some ESA-listed species”
Water Quality Quantity
- “roads carry sediment”
- “municipal water intakes sit in watersheds”
- “Keep our watersheds clean”
- “impaired streams”
Climate Carbon Storage
- “stored forest carbon in the coterminous United States”
- “quantify the change in carbon storage”
- “hold carbon”
Recreation Tourism Public Use
- “I hike to be outside in nature”
- “It is good for the soul”
- “stop developing every inch of the forest so our kids can know it”

What it names

Works cited: Kroeger et al. 2022

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The land is ours. Once it is gone, it's gone, and there are fewer places left. I am submitting these comments in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001, because what the agency is proposing to undo cannot be rebuilt once it is lost. I hike to be outside in nature. It is good for the soul. I look for wildlife and birds, and I believe the wildlife needs its space. The agency's own data make clear what opening these areas to roads does to birds specifically: the DEIS cites the 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. (Kroeger et al. 2022; McClure et al. 2013; Ware et al.) That is not a marginal effect. The agency must explain, in its response to these comments, how it expects bird communities to be protected across the affected landscape if this rule is rescinded. The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. That range is cited and then set aside. No projection of what it means across 40.1 million acres of potentially affected environment appears anywhere in the document. I ask that the agency apply that cited fragmentation range to the full 40.1 million acres before this rulemaking goes any further. The agency's own citation addresses what roads do to large animals too. 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 is noted and dropped. No population-level projection follows. The agency should project the effects on big game populations and hunter opportunity under each alternative and put that analysis before the public. I have been on mountain roads that were dangerous because they were not maintained. It does not make sense to spend money to build more roads when there is not enough money to maintain the ones that already exist. Beyond the dollars, roads carry sediment. The agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale, and more than 7,000 municipal water intakes sit in watersheds fed by these roadless areas. Keep our watersheds clean. Fewer than 12 percent of those watersheds have impaired streams today, and the agency should explain on the record how that number will not grow if road construction is permitted to expand into country that has none. On carbon: The DEIS cites the estimate that these inventoried roadless areas contain about 5 percent of the stored forest carbon in the coterminous United States, roughly 0.9 billion metric tons. The document then concludes the lands will continue to sequester and store carbon, with no analysis of what harvest and roading would change. That is not analysis, it is assumption. The agency must quantify the change in carbon storage and sequestration under each alternative. The most serious failure in this record is what the agency's own biological assessment finds and then proposes to do nothing about. The agency's 428-page draft biological assessment closes: "Rescinding the 2001 Roadless Rule will increase the likelihood of road construction and timber harvests occurring in locations previously considered inventoried roadless areas. In many cases the Forest Service anticipates this increased activity to adversely affect some ESA-listed species and their designated critical habitats." The DEIS tallies the determinations: "may affect, likely to adversely affect" for 327 ESA-listed species and 71 designated critical habitats. The agency wrote those words. It anticipates the harm and proposes no mitigation. I ask that the agency disclose, species by species, how the likely adverse effects its own biological assessments identify will be avoided or mitigated, and that ESA consultation be completed and published before any final rule is issued. We need to stop developing every inch of the forest so our kids can know it. The Forest Service held more than 600 public meetings and took 1.6 million comments to write this rule. It has held none to undo it. A logged stand grows back. A road does not. The smoke from fire season is already so bad that you cannot go outside in town, cannot open windows, and it reaches people many miles from any fire. These lands filter water, hold carbon, and give wildlife the space it needs. They are not ours to spend. They belong to future generations too, and the agency should manage them that way.