Comment Analysis · Docket FS-2025-0001

FS-2025-0001-563527

Opposes rescissionA2 moderateSubstance 12/24Owed an answerPosted October 5, 2026 On Regulations.gov

In short: The comment documents specific deficiencies in the agency's analysis regarding wildlife habitat impacts, small business economic effects, reliance interests, plan amendment scenarios, and wildfire risk, citing specific data from the DEIS and Federal Register notices to support the request for further analysis and explanation.

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
- “Creatures that need protection: bison, wolves, elk, moose, hummingbirds, and even spiders are all part of our natural world and deserve a clean, safe home”
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
- “ideal summer elk habitat is unroaded land with cover and forage”
- “Building roads into these areas would directly harm the animals I care about”
Water Quality Quantity
- “1,034 municipal water intakes sit in watersheds containing affected roadless areas”
- “California holds 381 inventoried roadless areas totaling 4,389,760 acres”
- “These are not abstractions”
Recreation Tourism Public Use
- “I have ridden my bicycle on trails in nearly every state in the country”
- “People who lead bicycle tours and wildlife trips through these forests are exactly the small businesses that would feel this loss first”
- “My own riding and my own wildlife watching in these forests are reliance interests”
Forest Management Wildfire
- “Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas”
- “human-caused ignitions increase in abundance with proximity to roads”
- “The agency has not quantified the expected increase in human-caused ignitions that would follow new road access”

What it names

National Forests: Shasta-Trinity National Forest Six Rivers National Forest
Roadless areas: Cow CreekSouth Fork

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 Creatures that need protection: bison, wolves, elk, moose, hummingbirds, and even spiders are all part of our natural world and deserve a clean, safe home. I have ridden my bicycle on trails in nearly every state in the country. Our natural places are one of the greatest things we have going for us. They need protecting. Rescinding the 2001 Roadless Area Conservation Rule would threaten both, and I oppose it. The roadless areas I am most concerned about are the South Fork area of 16,786 acres and the Underwood area of 3,046 acres in the Shasta-Trinity National Forest, and the Cow Creek area of 1,271 acres in the Six Rivers National Forest, all in California. California holds 381 inventoried roadless areas totaling 4,389,760 acres, and across the Pacific Southwest region, 1,034 municipal water intakes sit in watersheds containing affected roadless areas. These are not abstractions. On wildlife: the DEIS itself documents that habitat fragmentation reduces biodiversity by 13 to 75 percent, 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. The agency's own words acknowledge that wide-ranging mammals like the grizzly bear "have suffered habitat loss and the extirpation or fragmentation of their populations." The elk I hope to see in places like South Fork depend on exactly the kind of habitat this rule protects. The agency's own sources found that elk survival rates rose during a road closure and fell again when the gates were removed, and that ideal summer elk habitat is unroaded land with cover and forage. For moose, the DEIS notes they are drawn to road corridors for road salt, increasing human-moose conflict, and the agency's own Tribal record credits the rule's protection with the recovery of deer and moose populations by preserving old-growth winter shelter. Building roads into these areas would directly harm the animals I care about. I ask the agency to explain specifically how it reconciles these findings with the proposal to lift protections. The agency's small-business analysis cannot be reconciled with its own cost figures. The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. The supporting analysis reaches its no-impact conclusion by spreading losses across every small firm in the sector nationally, not the outfitters and guides actually holding permits in the affected areas. People who lead bicycle tours and wildlife trips through these forests are exactly the small businesses that would feel this loss first. The agency should withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. The agency invited reliance interests and then declined to weigh them. The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. My own riding and my own wildlife watching in these forests are reliance interests. An agency changing course must account for what its prior policy encouraged people to count on. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. The agency's treatment of future plan amendments is internally contradictory. The proposed rule concedes that subsequent land management plan amendments and revisions "could increase the area where timber harvest and road construction would be allowed," declares changes to plans beyond the scope of the proposal, and then requests public comment on them (91 FR 53830). Inviting comment on a scenario the agency refuses to analyze is not a substitute for analysis. The foreseeable plan-amendment scenario, including expanded timber harvest area, must be analyzed as part of this action, not deferred to a later process that commenters cannot yet reach. Finally, the agency's own fire data undermines the proposal's safety rationale. Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads. The trails I ride and the animals I look for do not survive catastrophic fire any better than they survive bulldozers. The agency has not quantified the expected increase in human-caused ignitions that would follow new road access, nor weighed that increase against any claimed reduction in wildfire hazard. That calculation belongs in this record before any final decision is made. Sincerely, Molly Martin Eureka, California