Comment Analysis · Docket FS-2025-0001

FS-2025-0001-542750

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

In short: The comment documents specific analytical deficiencies in the DEIS regarding the Wolfpen roadless area, including the failure to reconcile wildfire ignition data with fuels management goals, the lack of application of cited fragmentation and carbon storage statistics to the affected acreage, and the absence of projected population-level consequences for listed species and big game.

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
- “shelters more than 5,000 Virginia big-eared bats”
- “supports the Indiana bat, the Kentucky arrow darter, the blackside dace, and the northern long-eared bat”
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
- “elk avoid roads and select unroaded habitat”
Water Quality Quantity
- “headwater streams feed the Red River”
- “Kentucky's only National Wild and Scenic River”
- “Wolfpen roadless area... represents Kentucky's entire inventoried roadless inventory”
Climate Carbon Storage
- “inventoried roadless areas contain about 5 percent of the stored forest carbon”
- “roughly 0.9 billion metric tons”
- “quantify the change in carbon storage and sequestration under each alternative”
Governance Policy Process
- “procedural and analytical failures in the current proposal”
- “The agency must explain in plain terms what effects on these species it projects”
- “The Forest Service held more than 600 public meetings... It has held none to undo it”

What it names

National Forests: Daniel Boone National Forest
Roadless areas: Wolfpen

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 Daniel Boone National Forest is a treasure that must be protected, and the proposal to rescind the Roadless Area Conservation Rule puts it directly at risk. Public land should be preserved for future generations. If not protected, everything will be used up. This is sacred land, and the procedural and analytical failures in the current proposal demand a response. The Wolfpen roadless area, at 2,835 acres, represents Kentucky's entire inventoried roadless inventory, a single area whose headwater streams feed the Red River, Kentucky's only National Wild and Scenic River. The same landscape shelters more than 5,000 Virginia big-eared bats in deep sandstone overhangs of the Red River Gorge, roughly 40 percent of the global population of a federally endangered species. The Daniel Boone also supports the Indiana bat, the Kentucky arrow darter, the blackside dace, and the northern long-eared bat. Rescission here is not an abstraction; it is a decision about this one finite area and every listed species it holds. The agency must explain in plain terms what effects on these species it projects under the proposed action, and it must do so with reference to its own inventory data. The agency's own record undermines the wildfire rationale offered for rescission. The DEIS states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal does not reconcile this finding with its conclusion that opening roadless areas to road construction advances fuels management goals. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence and fuel treatment in roadless areas, and that it reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. The DEIS raises fragmentation and then abandons it. The document states: "The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent." That range is presented and never applied. No projection across the 40.1 million acres of potentially affected environment follows from it. The agency must apply its own cited fragmentation range to that full acreage before this proposal can be considered analytically complete. The same pattern holds for wildlife. The DEIS states: "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 consequence for big game is projected anywhere in the document. What does that pattern of avoidance and survival mean at the scale of this action? The agency should project the effects on big game populations and hunter opportunity under each alternative. Carbon storage receives the same treatment. The DEIS states: "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 these lands will continue to sequester and store carbon, with no analysis of what harvest and roading would change. That conclusion, unsupported by any quantified alternative-by-alternative comparison, is not analysis. The agency must quantify the change in carbon storage and sequestration under each alternative before finalizing any decision. Future generations should not inherit fewer of these places. The Forest Service held more than 600 public meetings and took 1.6 million comments to write the rule. It has held none to undo it. That asymmetry alone warrants scrutiny, and every unresolved analytical gap identified above makes the case for keeping the rule exactly where it stands. Concerned citizen in Kentucky