Comment Analysis · Docket FS-2025-0001

FS-2025-0001-542732

Opposes rescissionA3 weakSubstance 9/24Owed an answerPosted October 4, 2026 On Regulations.gov

In short: The comment establishes that the agency's DEIS and Cost Benefit Analysis fail to project population-level effects on birds and big game, quantify carbon storage changes, or reconcile the $6.9 billion road maintenance backlog with the proposed rescission, specifically regarding named roadless areas in Wisconsin, Michigan, and Indiana.

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

A3 weak: Substantive, but easier to set aside.

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.
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.
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.
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
- “I watch for birds, including migrating birds, and other wildlife”
- “Bird richness declines with road presence in forested habitat”
- “elk survival rates increased during a road closure and decreased when the gates were removed”
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
Climate Carbon Storage
- “Carbon storage is acknowledged and then effectively ignored”
- “inventoried roadless areas contain about 5 percent of the stored forest carbon”
- “quantify the change in carbon storage and sequestration under each alternative”
Water Quality Quantity
- “Wisconsin's roadless watersheds also supply drinking water to communities”
- “286 municipal water intakes sit in watersheds containing affected roadless areas”
- “expanding the road network puts both ecological integrity and water supply at risk”
Economic Impact Fiscal
- “The record the agency assembled does not support rescission on economic grounds”
- “net present value spanning negative $92 million to positive $199 million”
- “expanding a road system that already carries a $6.9 billion maintenance backlog is fiscally responsible”

What it names

National Forests: Chequamegon-Nicolet National Forest Hoosier National Forest Huron-Manistee National Forest
Roadless areas: Bear SwampMogan Ridge

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 The forests closest to me, and every forest in this country, are at stake in this proceeding. I watch for birds, including migrating birds, and other wildlife, and I am filing this comment in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001). The roadless areas I am most connected to include Perch Lake, Shelp Lake, Shoe Lake Islands, and Wheeler Lake Islands in the Chequamegon-Nicolet National Forest in Wisconsin, as well as Bear Swamp in the Huron-Manistee National Forest in Michigan and Mogan Ridge in the Hoosier National Forest in Indiana. These are places worth protecting without qualification, and the agency has not made a credible case for opening them. The record the agency assembled does not support rescission on economic grounds. The DEIS itself states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against that baseline, the agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year, with a net present value spanning negative $92 million to positive $199 million. That range cannot establish a net benefit. It also cannot explain how expanding a road system that already carries a $6.9 billion maintenance backlog is fiscally responsible. I ask the agency to reconcile the proposal with these figures in the record and explain how a Cost Benefit Analysis with that spread justifies this action. Bird richness declines with road presence in forested habitat. The DEIS documents this directly, finding that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. I watch for birds, including migrating species, in these forests. The areas I named are among the nearest to me, and Perch Lake alone covers 2,390 acres of the Chequamegon-Nicolet, part of a Wisconsin roadless inventory totaling 68,987 acres across 16 areas. Fragmentation of that habitat does not produce a modest, manageable effect. "The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent." That range appears in the document and then disappears; no projection across the 40.1 million acres of potentially affected environment follows. I ask the agency to apply that cited range to the full affected acreage and explain what it means for bird populations specifically. The agency documents the relationship between roads and wildlife and then sets the finding aside. "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." No population-level effect on big game is projected anywhere in the document. The agency should project the effects on big game populations and hunter opportunity before finalizing any alternative. Carbon storage is acknowledged and then effectively ignored. "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 DEIS concludes these lands will continue to sequester and store carbon, but that conclusion does not account for harvest and roading under the action alternatives. The agency must quantify the change in carbon storage and sequestration under each alternative, not assert continuity while proposing development. We do not want roads going through our parks, our forests, our sacred lands. That is a simple and sufficient statement of interest, and it applies to every single forest in this country, not only the ones nearest to me. Wisconsin's roadless watersheds also supply drinking water to communities: across the Eastern region, 286 municipal water intakes sit in watersheds containing affected roadless areas. Fragmenting these forests and expanding the road network puts both ecological integrity and water supply at risk. The agency has not answered the basic question its own data raises. I ask that it do so. Sincerely, Jen Curley Chicago, IL