Comment Analysis · Docket FS-2025-0001

FS-2025-0001-567540

Opposes rescissionA2 moderateSubstance 13/24Owed an answerPosted October 5, 2026 On Regulations.gov

In short: The comment documents that the agency's DEIS and Cost Benefit Analysis contain internal contradictions regarding wildfire risk, bird habitat loss, and net economic benefits, and asserts that the agency failed to weigh the specific reliance interests of Florida residents in the roadless areas of Osceola, Ocala, and Apalachicola National Forests.

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, 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.
  • 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
    • “Woodpeckers, storks, sparrows, and really any birds I can locate”
    • “bird richness declines with road presence in forested habitat”
    • “recovered red-cockaded woodpeckers from 7 breeding pairs to 98 family groups”
    • “Florida scrub-jays, found nowhere else on the planet, depend on the surrounding scrub”
  • Water Quality Quantity
    • “Ocala alone sits directly above the Floridan Aquifer”
    • “road construction is a direct contamination pathway to the drinking water supply”
    • “378 municipal water intakes sit in watersheds containing affected roadless areas”
  • Recreation Tourism Public Use
    • “Photography pulled me into the forests of Florida”
    • “paddling the river and listening to the birds and watching the wildlife is the whole point”
    • “recreation losses of at least $6.1 million a year”
    • “Gum Bay, 11,645 acres in Apalachicola National Forest, is serene, with springs and rivers I want to explore”
  • Forest Management Wildfire
    • “The strongest reason to keep the rule is fire”
    • “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
    • “far higher fire density on roaded land than inside the affected roadless areas”

What it names

National Forests
Apalachicola National ForestOcala National ForestOsceola National Forest
Roadless areas
Alexander Springs CreekFarles PrairieGum BayImpassable BayNatural Area Wsa

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 Photography pulled me into the forests of Florida, and the forests kept me there. I go looking for anything and everything beautiful to photograph. It is a way for me to memorialize the things I find beautiful, and the roadless areas of Osceola, Ocala, and Apalachicola National Forests are where I find them. Woodpeckers, storks, sparrows, and really any birds I can locate on the trails I walk. Rescinding the 2001 Roadless Area Conservation Rule would take that from me, and I am filing this comment to say it must not happen. The strongest reason to keep the rule is fire, and the agency's own record says so. 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 justifies rescission in part on fuels management grounds, yet that language is sitting in the agency's own draft environmental impact statement. The agency must explain why its proposal departs from those findings, and it must reconcile the rescission with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. Birds are why I hike. Losing road protection in these forests is not a neutral trade. The DEIS cites 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. At Alexander Springs Creek in Ocala National Forest, paddling the river and listening to the birds and watching the wildlife is the whole point. If I lost that place I would not have access to a nature spot to just enjoy nature's music. Natural Area Wsa and Impassable Bay in Osceola National Forest hold migratory birds and federally protected animals I can see nowhere else near me. The Ocala National Forest specifically recovered red-cockaded woodpeckers from 7 breeding pairs to 98 family groups because the longleaf pine stands they need have never been fragmented by roads. Florida scrub-jays, found nowhere else on the planet, depend on the surrounding scrub. I ask the agency to explain in the record how opening these forests to roads is compatible with those documented bird outcomes. The economic case for rescission also does not hold. The agency's own record acknowledges: "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." The agency must reconcile the proposal with its own Cost Benefit Analysis, which 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 and a net present value spanning -$92 million to +$199 million, and it must say plainly how an action whose own numbers cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog. Pinhook, 15,405 acres in Osceola National Forest, is part of old Florida and what makes Florida, Florida. Farles Prairie in Ocala, 1,901 acres, is a hidden gem that combines water and trees. Gum Bay, 11,645 acres in Apalachicola National Forest, is serene, with springs and rivers I want to explore. These are the places I rely on. 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. The agency is required to identify and weigh the reliance interests described in the comments it receives. This comment is one of them, and it deserves a real accounting. Florida holds 9 inventoried roadless areas totaling 50,482 acres, and the Ocala alone sits directly above the Floridan Aquifer, where road construction is a direct contamination pathway to the drinking water supply of central Florida. Across the Southern region, 378 municipal water intakes sit in watersheds containing affected roadless areas. We need to protect our environment. The rescission should be withdrawn. Sincerely, A born and raised Florida Native

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