Comment Analysis · Docket FS-2025-0001

FS-2025-0001-575951

Opposes rescissionA1 strongSubstance 14/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment establishes that the agency's proposed rescission of the Roadless Area Conservation Rule is internally inconsistent with its own DEIS findings regarding water contamination risks in the Ocala National Forest, increased wildfire incidence on roaded lands, and negative net economic benefits, while failing to address prior judicial rejections of state-by-state frameworks.

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

A1 strong: Must be answered — it names the law.

Owed an answer on Analytical gap, Evidence, Legal.

Standard dismissals it defeats

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.
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.
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.

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.
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.

Topics

Water Quality Quantity
- “direct contamination pathway for the drinking water supply”
- “Ocala sits directly over the Floridan Aquifer”
- “378 municipal water intakes sit in watersheds containing affected roadless areas”
Wildlife Habitat
- “scrub jays that exist nowhere else on the planet”
- “roads fragment and degrade”
- “recovery of deer populations in other regions by preserving unroaded winter habitat”
Forest Management Wildfire
- “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”
- “Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “recreation losses of at least $6.1 million a year”
- “road system it proposes to expand already carries a $6.9 billion maintenance backlog”

What it names

National Forests: Ocala National Forest Osceola National Forest
Roadless areas: Alexander Springs CreekFarles Prairie
Law cited: 36 C.F.R. Section 294.12

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeEA analysisAnalytical gapEvidenceRequest

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I wanted to state that clearly in case these are only skimmed over or read for the first few thoughts. My name is Kaitlyn Schirard and I'm from Florida. The wild spaces I care most about cannot speak for themselves. That is the point. Whether I am exploring the scrublands and wetlands of Ocala National Forest, watching deer move through the pinelands, or catching sight of scrub jays along the way, what makes those moments possible is the simple fact that those lands remain intact. Alexander Springs Creek and Farles Prairie in the Ocala, and the Pinhook tract in Osceola National Forest, are places whose value lies precisely in what has not been done to them. Rescinding the 2001 Roadless Area Conservation Rule would put that at risk, and this letter asks the agency to answer for what its own record says before it acts. The Ocala sits directly over the Floridan Aquifer, and Alexander Springs, a first-magnitude spring inside the forest, moves water through karst limestone where any road construction becomes a direct contamination pathway for the drinking water supply of central Florida. Florida holds 9 inventoried roadless areas totaling 50,482 acres under the current rule's protection, and across the Southern region, 378 municipal water intakes sit in watersheds containing affected roadless areas. These are not abstractions. The deer I watch in these forests, and the scrub jays that exist nowhere else on the planet, depend on landscape conditions that roads fragment and degrade. The agency's own record acknowledges that road construction may alter deer migration routes and increase movement speed, citing research on exactly that disruption, and credits roadless protections with the recovery of deer populations in other regions by preserving unroaded winter habitat. I ask that the agency explain, specifically and concretely, how the proposed rescission accounts for those documented harms to wildlife that its own analysis has already identified. On wildfire, the agency argues that rescission is partly justified by the need for fuels management access. But the agency's own text 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." That sentence is in the agency's own draft environmental impact statement. I ask the agency to explain why the proposal departs from that prior finding, and to reconcile the rescission with its own DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic case for rescission is no stronger. The agency's own record states: "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." Against that baseline, the agency's own cost-benefit analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service, set against recreation losses of at least $6.1 million a year and a net present value ranging from -$92 million to +$199 million. The agency cannot establish a net benefit from its own numbers, while the road system it proposes to expand already carries a $6.9 billion maintenance backlog. The proposal also argues that state-by-state approaches can replace a national rule, but the agency's record acknowledges: "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The agency tried this before, and courts rejected it. I ask the agency to address how this proposal avoids the deficiencies the Ninth Circuit identified the last time a state-by-state framework was substituted for national protection, and to explain its own prior finding that local decision-making can incrementally erode nationally significant roadless values. Finally, the rule as written already accommodates the administrative concerns the agency raises. The agency's own text confirms: "It generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." Before claiming the rule is too rigid to function, the agency must identify which specific burdens fall outside those existing exceptions and quantify them in the record. A gross twisting of land stewardship is how I would describe an action that cannot survive scrutiny of its own supporting documents.