Comment Analysis · Docket FS-2025-0001

FS-2025-0001-572130

Opposes rescissionA2 moderateSubstance 14/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment documents specific deficiencies in the agency's DEIS, including the failure to apply cited fragmentation and fire risk data to the 40.1 million acres of affected land, the improper averaging of small entity economic impacts, and the failure to weigh stated reliance interests, while asserting the commenter's standing based on recreational use and reliance on the existing rule.

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
- “paddle rivers that still function as critical bird and wildlife corridors”
- “elk avoid areas near roads and select habitat away from them”
- “roads built for oil extraction may have altered mule deer migration routes”
- “bird richness declines with road presence in forested habitat”
Water Quality Quantity
- “Clean water is becoming more and more at risk”
- “roads and their facilities can produce up to 90 percent of the sediment from a timber sale”
- “degraded watersheds and higher treatment costs”
Recreation Tourism Public Use
- “What I want from public land is simple: no vehicles”
- “immerse myself in nature”
- “lost recreation benefit at a minimum of $6.1 million a year”
- “outfitters, guides and tour operators as affected”
Legal Regulatory Framework
- “The proposed rule certifies no significant impact on small entities”
- “The certification should be withdrawn”
- “reliance interests in the current rule that could be affected”
- “The agency must identify and weigh the reliance interests”

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 What I want from public land is simple: no vehicles. I want to immerse myself in nature, to paddle rivers that still function as critical bird and wildlife corridors and need to stay away from vehicles, to look for elk, deer, bears, bobcats, and every seasonal bird the landscape carries. The Roadless Area Conservation Rule protects the conditions that make those things possible, and this administration's proposal to rescind it is something I oppose without reservation. The public is a strong supporter of this rule, and so am I. The wildlife science alone should give the agency pause. I look for elk, and the agency's own record shows that elk avoid areas near roads and select habitat away from them, that elk survival rates rose during a road closure and fell again when the gates were removed. For deer, the DEIS cites Wyoming research finding that roads built for oil extraction may have altered mule deer migration routes and increased their movement speed, disrupting the unroaded security the animals depend on. When I paddle rivers and listen for the seasonal birds those corridors carry, I am relying on exactly the kind of quiet the rule preserves. 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. The agency has its own numbers. I ask that it explain, on the record, how opening these areas to road construction squares with the documented effects on the species its analysis names. That analysis also documents a fragmentation penalty the agency has declined to apply to its own proposal. "The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent." That range appears, and then nothing follows from it. No projection is made across the 40.1 million acres of potentially affected environment. A number that severe, cited in the agency's own document, demands application. I ask that the agency carry the cited fragmentation range across the 40.1 million acres of potentially affected environment and explain why it chose not to do so in the current draft. Roads also lead to invasive weeds, washouts, and other issues that degrade the experience and the land itself. The fire data the agency compiled reinforces this. "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 agency cannot simultaneously cite that gap and claim road-building reduces fire risk without quantifying the expected increase in human-caused ignitions from new access and weighing it honestly against the claimed hazard reduction. That accounting is missing from the current proposal. Clean water is becoming more and more at risk due to the actions of this administration, and that is absolutely unacceptable. The cost of treating increasingly polluted water falls onto average Americans, not onto the industries that benefit from the roads. The agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale, and the agency is already billions behind on maintaining the roads it has. Building new ones into country that has none compounds a burden the public will bear through degraded watersheds and higher treatment costs. The regulatory record has problems that go beyond the substance. "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." That certification is reached by averaging losses across every small firm in the sector nationally, not by assessing the outfitters and guides who actually hold permits in the affected areas. The agency concedes some of those firms may lose those receipts. The certification should be withdrawn and the impact assessed on the entities actually operating in the potentially affected roadless areas, not the national average firm. Finally, 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. My use of these areas, and my expectation that the rule protecting them would remain in place, is a reliance interest the agency invited and has not addressed. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before any final action. Sincerely, Jenny Russell Telluride, CO 81435