Comment Analysis · Docket FS-2025-0001

FS-2025-0001-568980

Opposes rescissionA2 moderateSubstance 11/24Owed an answerPosted October 5, 2026 On Regulations.gov

In short: The comment establishes that the DEIS fails to project the cited 13-75% biodiversity loss from fragmentation across 40.1 million acres, omits carbon storage analysis for harvest and roading despite citing 0.9 billion metric tons of stored carbon, ignores its own biological assessment finding likely adverse effects on 327 ESA-listed species, and excludes foreseeable plan amendments from analysis despite acknowledging they could expand timber harvest areas.

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
- “watch wildlife and birds”
- “lives in unbroken habitat”
- “harm to 327 protected species”
- “adversely affect some ESA-listed species”
Climate Carbon Storage
- “holding carbon”
- “stored forest carbon”
- “0.9 billion metric tons”
- “quantify the change in carbon storage”
Environmental Protection Biodiversity
- “habitat fragmentation reduces biodiversity”
- “lose its only federal protection”
- “retain the 2001 rule's protections”
- “unbroken habitat”
Governance Policy Process
- “Foreseeable plan amendments are placed beyond scope”
- “declares changes to plans beyond the scope”
- “analyze in the DEIS an alternative”
- “provide a reasoned explanation for it on the record”

What it names

National Forests: Olympic National Forest
Roadless areas: Green Mountain

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule. THE CLOSEST ROADLESS AREA TO MY ZIP CODE, 98115, IS GREEN MOUNTAIN IN OLYMPIC NATIONAL FOREST, WASHINGTON, ABOUT 34 MILES AWAY. THE 10 NEAREST AREAS HOLD 141,346 ACRES. EVERY ONE OF THEM STANDS TO LOSE ITS ONLY FEDERAL PROTECTION UNDER THE CURRENT PROPOSAL. I raise the following issues for the record and ask that the agency respond to each of them: Issue 1: Fragmentation is quantified and not applied I go out to watch wildlife and birds, and what I look for lives in unbroken habitat. The agency measured what fragmentation costs and then set the finding aside. The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. The number appears; no projection across the 40.1 million affected acres follows. I ask that the agency apply the cited fragmentation range to the 40.1 million acres of potentially affected environment. Issue 2: Carbon is stated and dropped The standing forests where I watch wildlife are doing quiet work the whole time, holding carbon. The agency states what these lands store and then drops the analysis. 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 DEIS concludes these lands will continue to sequester and store carbon, with no analysis of harvest and roading. I ask that the agency quantify the change in carbon storage and sequestration under each alternative. Issue 4: The agency's own assessments predict harm to 327 protected species I spend my time looking for wildlife in these forests, and the rarest of it is exactly what the agency's own assessments say this action is likely to harm. The agency's 428-page draft biological assessment closes: "Rescinding the 2001 Roadless Rule will increase the likelihood of road construction and timber harvests occurring in locations previously considered inventoried roadless areas. In many cases the Forest Service anticipates this increased activity to adversely affect some ESA-listed species and their designated critical habitats." The DEIS tallies the determinations: "may affect, likely to adversely affect" for 327 ESA-listed species and 71 designated critical habitats. I ask that the agency disclose, species by species, how the likely adverse effects its own biological assessments identify will be avoided or mitigated, and that ESA consultation be completed and published before any final rule. Issue 5: Foreseeable plan amendments are placed beyond scope I want my kids to have this, and what happens after this rule is the part that reaches them. The agency admits the next step and refuses to analyze it. 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). The agency is asking commenters to perform the analysis it declared out of scope. I ask that the agency analyse the foreseeable plan-amendment scenario, including expanded timber harvest area, as part of this action. I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule's protections. Where this proposal rests on factual conclusions that differ from the agency's own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record. Sincerely, Grace Nordhoff Seattle, WA 98115