Comment Analysis · Docket FS-2025-0001

FS-2025-0001-551208

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

In short: The comment establishes that the DEIS habitat baseline at page 141 omits the Dietz et al. (2021) finding regarding the concentration of vulnerable species in inventoried roadless areas, despite the study being cited in the DEIS Volume III, and requests supplementation of the analysis under 7 CFR 1b.7(f)(2)(iii) to incorporate this 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

Wildlife Habitat
- “No more wildlife”
- “endangered and protected species on this land”
- “308 species, or 57%, have at least some suitable habitat in inventoried roadless areas”
- “concentrated at-risk wildlife habitat”
Water Quality Quantity
- “No more clean water”
- “provides water for people to drink”
Environmental Protection Biodiversity
- “No more beautiful forests”
- “land around it would suffer”
- “preserve wilderness”
Scientific Research Evidence
- “Dietz, M. S., Barnett, K., Belote, R. T., & Aplet, G. H. (2021)”
- “Global Ecology and Conservation vol. 32”
- “incorporate the Dietz et al. 2021 finding into the habitat discussion”

What it names

Law cited: 7 CFR 1b
Works cited: 10.1016/j.gecco.2021.e01943

The comment

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

I really don't want this. If roads were to come into to place, the land around it would suffer. No more wildlife. No more clean water. No more beautiful forests. When I get older I desperately want to see the world. See it's animals and landscapes. But none of that is going to happen if these roads are built. Forests and mountains are a huge part of everyone's lives. It provides water for people to drink and can attract tourists to look at the environment. There are plenty of endangered and protected species on this land and all of them are going to die unless the roads don't go through. I know this comment is quite short but I'm glad I am able to express my view and where I stand in this. DON'T BUILD THE ROADS !! Critical-Habitat Counts Untraceable to the Incorporated Biological Assessments, and an Omitted Roadless-Specific Species Finding The DEIS's habitat baseline states, at page 141 (Chapter 3, "Assumptions Common to All Alternatives" - "Potentially Affected Environment" - "Habitat"): "Within the potentially affected environment there are 79 final or proposed critical habitats designated under the Endangered Species Act for species managed by USFWS and 19 critical habitats designated for species evolutionarily significant units or distinct population segments managed by NMFS." Two defects in that passage require correction in the FEIS. I state them as separate requests. The habitat baseline omits the one published finding in this record that is specific to inventoried roadless areas and to species of conservation concern. The baseline reports that the potentially affected environment "provides habitat for more than 300 threatened, endangered, and proposed species" and gives the two critical-habitat counts. It reports nothing about how concentrated at-risk wildlife habitat is inside inventoried roadless areas, although the record contains a published measure of exactly that. Dietz, M. S., Barnett, K., Belote, R. T., & Aplet, G. H. (2021), "The importance of U.S. national forest roadless areas for vulnerable wildlife species," Global Ecology and Conservation vol. 32, doi:10.1016/j.gecco.2021.e01943, examined 537 terrestrial vertebrate wildlife species of conservation concern in the contiguous United States and found that "308 species, or 57%, have at least some suitable habitat in inventoried roadless areas, even though inventoried roadless areas only cover 2% of the area of the contiguous United States." This is not "science or literature not previously considered" within the meaning of 7 CFR 1b.7(f)(2)(iv). The agency has held this study since scoping: it is cited in the DEIS's own Volume III by the Attorneys General of Washington, California, Arizona, Massachusetts, Minnesota, New Mexico, Oregon, and Vermont at pages 37 through 39, by a Member of the House Committee on Natural Resources at page 415, and by other commenters at pages 498 and 506. It nonetheless does not appear in the DEIS's References Cited. The cause-and-effect link to this analysis is direct. The DEIS measures the affected environment by counts of listed entities - species, critical habitats - and that metric is blind to how concentrated vulnerable-species habitat is within the specific land base whose protections the proposed rescission would remove. It is the concentration, not the count, that determines the magnitude of the effect: 57 percent of the national pool of vulnerable terrestrial vertebrates has suitable habitat on 2 percent of the land area of the contiguous United States, and that 2 percent is the land base at issue in this rulemaking. A baseline that omits this understates what the rescission places at risk, and every effects conclusion tiered to that baseline inherits the understatement. I request supplementation of the analysis under 7 CFR 1b.7(f)(2)(iii): incorporate the Dietz et al. 2021 finding into the habitat discussion of the affected environment, add the study to the DEIS References Cited, and carry a roadless-specific measure of species-of-conservation-concern habitat through the effects analysis for each alternative, including the no-action alternative. Under 7 CFR 1b.7(f)(3), I request that the response to each of the two items above cite where in the FEIS or the supporting proposal record the action taken is accounted for.