Comment Analysis · Docket FS-2025-0001

FS-2025-0001-570624

Opposes rescissionA2 moderateSubstance 13/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment establishes that the agency's DEIS and Cost Benefit Analysis fail to apply cited scientific findings on bird abundance, habitat fragmentation, and fire ignition density to the specific 40.1 million acres of affected roadless areas, and that the regulatory flexibility analysis improperly uses national averages rather than assessing impacts on specific local small entities.

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
- “bird richness declines with road presence”
- “road-noise experiments... cut bird abundance by over a quarter”
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
Recreation Tourism Public Use
- “go for solitude and to experience wilderness”
- “ride trails throughout those forests”
- “visit natural wild places as a birder”
Forest Management Wildfire
- “Human-caused ignition density is 22.4 fires per million acres... against 3.0 inside the affected roadless areas”
- “human-caused ignitions increase in abundance with proximity to roads”
- “road access could increase the number and frequency of wildfires”
Legal Regulatory Framework
- “regulatory flexibility analysis deserves the same scrutiny”
- “certifies no significant impact on small entities”
- “obligated to identify and weigh the reliance interests”

What it names

Works cited: Kroeger et al. 2022

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 The national forests of the West are where I go for solitude and to experience wilderness. I ride trails throughout those forests, and I visit natural wild places as a birder looking for birds. The proposed rescission of the 2001 Roadless Area Conservation Rule threatens every reason I go there, and I oppose it. The agency's own evidence on birds makes the harm concrete. 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. (source: DEIS; Kroeger et al. 2022; McClure et al. 2013; Ware et al.) These are not projections from outside the record; the agency put them there. Opening roadless areas to road construction would introduce exactly the road presence and noise that the cited research shows cuts richness, cuts abundance, and drives a significant share of species away entirely. The agency has not applied these findings to any estimate of what birds lose across the affected landscape. I ask the agency to do that analysis and make it part of the record before any final action is taken. The regulatory flexibility analysis deserves the same scrutiny. 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 certification reaches its conclusion by spreading loss across every small firm in the sector nationally rather than examining the outfitters and guides actually holding permits in the affected areas, and the analysis itself concedes that some firms may lose those receipts. That is not a meaningful assessment of impact on the entities who will actually bear it. 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. On reliance, 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. This comment is one such interest. I have organized my time in the West, my birding, my riding, and my pursuit of solitude around the expectation that these areas remain protected. An agency changing course is obligated to identify and weigh the reliance interests its prior policy created. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. The fire analysis in the DEIS also points the wrong direction for the proposal. 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 effects analysis concedes that road access could increase the number and frequency of wildfires. Yet no quantification of that increase appears. The agency should quantify the expected rise in human-caused ignitions that would follow new road access and weigh it honestly against whatever wildfire hazard reduction it claims as a benefit. Finally, The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. That range appears in the record and then stops. No projection across the 40.1 million acres of potentially affected environment follows from it. A cited finding that the agency declines to apply to the scale of the action it is taking is not analysis; it is decoration. The agency must apply the cited fragmentation range to the 40.1 million acres of potentially affected environment and show what that means for the decision before it. Sincerely, Anne Jestadt Boise, Idaho