Comment Analysis · Docket FS-2025-0001

FS-2025-0001-548857

Opposes rescissionA3 weakSubstance 11/24Owed an answerPosted October 4, 2026 On Regulations.gov

In short: The comment documents that the rescission of the 2001 Roadless Rule would exacerbate bird population declines and habitat fragmentation, citing specific data from the DEIS and external studies to support the request to maintain the rule via Alternative 1.

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 Evidence.

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
- “concerned about what effect rescinding the Roadless Rule will have on our bird populations”
- “birds that depend on intact roadless areas”
- “habitat fragmentation reduces biodiversity”
- “bird richness declines with road presence in forested habitat”
Environmental Protection Biodiversity
- “keep the Roadless Rule completely intact”
- “High quality habitat and conservation are essential”
- “industrial timber management... disrupted the mosaic of large old-growth areas”
- “We need more forests and wild areas, not less”
Scientific Research Evidence
- “2019 study... reported that bird populations had plummeted by 70%”
- “2025 State of the Birds Report... revealed that bird populations... have continued to experience consistent, steep declines”
- “DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent”
- “road-noise experiments in a roadless area cut bird abundance by over a quarter”

What it names

Works cited: Haddad et al. 2015Kroeger et al. 2022

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeAnalytical gapEvidenceRequestAlternative

Secretary Rollins, I am submitting this letter to express my strong opposition to the U.S. Forest Service proposal to fully or partially rescind the 2001 Roadless Area Conservation Rule. I urge the agency to fully support Alternative 1 (No Action) to keep the Roadless Rule completely intact. Our national forests and other public lands are a treasure and have been a central part of my life. I grew up hiking, camping and fishing with my family in the national forests of Colorado and Oregon. As a birder, I’m particularly concerned about what effect rescinding the Roadless Rule will have on our bird populations. I have experienced the wonder of seeing many birds that depend on intact roadless areas and careful management of our forest ecosystems: great grey owls, Clark’s nutcrackers, western tanagers, northern spotted owls, marbled murrelets, osprey and other raptors, to name a few. Unfortunately, in the last ten years, my husband and I have noticed how few birds there are as we hike trails in the Mount Jefferson Wilderness and visit estuaries at the Oregon coast. What we’ve been noticing has been part of a nation-wide story of bird loss. A 2019 study, [Decline of the North American avifauna, in the journal Science, (19 Sep 2019, Vol 366, Issue 6461, pp. 120-124) ] reported that bird populations had plummeted by 70% in the last 50 years. In real numbers, this was 3.3 billion birds, or 30% of the birds in North America that had disappeared by 2019. As to regional losses, there was an 11% decrease in Western forest birds, and 27% decrease in Eastern forest birds. Researchers estimated that forest bird populations have declined by 1.2 billion birds since 1970. In addition to this study, the 2025 State of the Birds Report by U.S. North American Bird Conservation Initiative (NABCI) at Cornell University revealed that bird populations across most habitats, including both Eastern and Western forests, have continued to experience consistent, steep declines. NABCI also reports that “…over 50% of western forest birds are declining due to habitat degradation from fire suppression and industrial timber management…” which has disrupted the mosaic of large old-growth areas and conifer and broadleaf forests that existed in the past. Building roads in forests on public lands further fragments habitat, and the concomitant extraction of timber or minerals degrades the environment even further. The agency’s own DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. (DEIS wildlife analysis; USFWS draft Biological Assessment; Haddad et al. 2015; McClure et al. 2013) High quality habitat and conservation are essential to turn around these declines. Forest conservation plans should go hand in hand with bird habitat conservation plans that employ sustainable forest management and fire-use practices that increase watershed resilience and benefit birds and people. In other words, turning around the decline in the bird populations includes forest restoration above and beyond the existing roadless areas in place now. That’s why it’s so important to not rescind any part of the 2001 Roadless Rule. In fact, the presence of a road is in itself very detrimental: 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. The birds leave before the trees do. (DEIS; Kroeger et al. 2022; McClure et al. 2013; Ware et al.) We need more forests and wild areas, not less. Roadless areas keep our forests intact as habitat for birds. In summary, fully or partially rescinding the Roadless Rule would be a devastating, irreversible mistake. I ask you to listen to the public, act responsibly, and do what is right for current and future generations. Keep the Roadless Rule entirely intact. Sincerely, Sarah Chaney Oregon