Comment Analysis · Docket FS-2025-0001

FS-2025-0001-575471

Opposes rescissionA2 moderateSubstance 11/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment establishes that the agency's DEIS and Biological Assessment fail to project the specific impacts of road construction and timber harvest on bird abundance, elk populations, carbon storage, and ESA-listed species across the 40.1 million acres of affected habitat, despite citing data showing significant declines in these areas, and requests that these projections and ESA consultations be completed before the final rule is adopted.

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 diverse wildlife firsthand”
- “bird richness declines with road presence”
- “elk avoid roads and select unroaded habitat”
- “adversely affect some ESA-listed species”
Climate Carbon Storage
- “stored forest carbon in the coterminous United States”
- “roughly 0.9 billion metric tons”
- “quantify the change in carbon storage and sequestration”
- “ignores what harvest and roading would do to that figure”
Environmental Protection Biodiversity
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
- “preserved as intact self-sufficient ecosystems”
- “327 ESA-listed species and 71 designated critical habitats”
- “destroyed if the roadless rule were overturned”
Water Quality Quantity
- “1,034 municipal water intakes sit in watersheds”
- “protect our remaining wild watersheds”
- “sustain our clean water supply”
- “Building new roads into country that currently has none”

What it names

Roadless areas: Santa Cruz

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 places I love most are deep in the woods, where I can see the stars at night, hear crickets, watch diverse wildlife firsthand, and smell clean air. These are places like no other, and they would be destroyed if the roadless rule were overturned. I photograph hawks and waterfowl in Northern California forests, in the Santa Cruz mountains where I used to live, and in parks like Yosemite. I go looking for nothing in particular, but I am always drawn to birds and other wildlife, photographing what I have the fortune to encounter when I am deep in the woods. I oppose the rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001, for that reason and for the reasons that follow. The agency's own draft environmental impact statement acknowledges that bird richness declines with road presence in forested habitat. More specifically, the DEIS cites the findings that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. California alone holds 381 inventoried roadless areas totaling 4,389,760 acres. The birds I photograph in those forests and mountains are not abstractions in a table: they are the wildlife those acres currently protect. Yet the DEIS cites these findings and draws no projection across the full extent of potentially affected habitat. Alongside this, the DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent, and then applies that range to nothing. I ask that the agency apply the cited fragmentation range to the 40.1 million acres of potentially affected environment, and explain in its response what that range means for bird communities specifically. The DEIS cites the finding that elk survival rates increased during a road closure and decreased when the gates were removed (Cole 1997), and that elk avoid roads and select unroaded habitat. This pattern, documented in the agency's own cited literature, receives no population-level projection anywhere in the document. The agency should project the effects on big game populations and hunter opportunity under each alternative, and that analysis should appear in the record before any final rule is adopted. I believe public land should be preserved as intact self-sufficient ecosystems that are not threatened by potentially dangerous human influences. The roadless rule has served that purpose. 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 then concludes that these lands will continue to sequester and store carbon, a conclusion that simply ignores what harvest and roading would do to that figure. The agency must quantify the change in carbon storage and sequestration under each alternative rather than asserting continuity it has not analyzed. The most direct evidence against rescission comes from the agency's own biological findings. 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. The agency anticipates harm and proposes no mitigation for it. 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. On the question of roads and resources: the roads in San Francisco, where I live, are crumbling, which makes conditions hazardous for cars and people. The roads regularly used by taxpayers affect the majority of people. The new roads this proposal would open serve a narrow interest: those who want to profit from lumber and recreation, a small minority. Across the Pacific Southwest region, which includes California, 1,034 municipal water intakes sit in watersheds containing affected roadless areas. We need to protect our remaining wild watersheds now more than ever. They sustain our clean water supply and support all life. Building new roads into country that currently has none, while diverting attention and funds from the infrastructure people depend on daily, adversely affects people's lives in both directions at once. The agency has not accounted for this tradeoff, and the record is incomplete without it. Sincerely, Rebecca Small San Francisco, CA