Comment Analysis · Docket FS-2025-0001

FS-2025-0001-576068

Opposes rescissionA1 strongSubstance 11/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment documents that the DEIS fails to project sediment delivery to 7,000 municipal intakes, does not apply cited fragmentation data to 40.1 million acres, and uses a flawed national averaging methodology for small entity economic impacts, while requesting specific quantifications and a withdrawal of the no-significant-impact certification.

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, 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
- “water that once held them becomes something else”
- “skid roads... main cause of soil erosion”
- “quantify projected sediment delivery to those more than 7,000 municipal intakes”
- “drinking water downstream”
Wildlife Habitat
- “populations decline, fish health deteriorates”
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
- “bird richness declines with road presence”
- “Birds, mammals, and reptiles all need these protected places”
Recreation Tourism Public Use
- “isolated wild places I have fished, hiked, and camped”
- “get somewhere not interrupted by the constant hum of vehicles”
- “lost recreation benefit at a minimum of $6.1 million a year”
- “outfitters, guides and tour operators as affected”
Economic Impact Fiscal
- “certifies no significant impact on small entities”
- “spreading expenditure losses across every small firm in the sector nationally”
- “infrastructure falls into disrepair because of personnel and budget constraints”
- “rational allocation of limited budget and personnel”

What it names

Law cited: 36 CFR 294.12
Works cited: Andrews et al. 2015

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 Fishing for sport and sustenance my entire life, I have watched first hand what happens when unmitigated negative pressures are placed on fish habitats: populations decline, fish health deteriorates, and the water that once held them becomes something else. The isolated wild places I have fished, hiked, and camped in for many, many years are not simply recreation areas. They are the places where it is still possible to get somewhere not interrupted by the constant hum of vehicles and construction. Rescinding the 2001 Roadless Area Conservation Rule would foreclose that possibility for the public and for the ecosystems that depend on undisturbed ground. The agency's own document acknowledges that skid roads, trails, log landings and similar disturbances within timber sale areas are the main cause of soil erosion and "can contribute up to 90 percent of the sediment generated by timber sale activity." That figure is stated and then left to stand alone. No projection of what that sediment load means for the people drinking water downstream appears anywhere in the analysis. The DEIS tells us that "Approximately 24 million people use water originating within the potentially affected roadless areas, through more than 7,000 municipal intakes, and less than 12 percent of these watersheds are currently impaired." Citing a number of that scale while offering no projection of sediment delivery to those intakes is not analysis, it is an omission. I ask that the agency quantify projected sediment delivery to those more than 7,000 municipal intakes as part of any final record of decision. I also ask that the agency identify, forest by forest, which plan provisions are enforceable substitutes for the protections currently found at 36 CFR 294.12 and 294.13, because the DEIS asserts that forest plans address municipal drinking water sources without naming a single binding provision that would do so. I venture into wild places specifically to see where the natural world acts with minimal human interference, and birds are a large part of what draws me there. Roads are, as I have observed across many habitats, the biggest cause of fragmentation. The DEIS supports that view numerically: it cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. It also carries 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. Birds, mammals, and reptiles all need these protected places to help balance the development occurring elsewhere. What the DEIS does not do is apply the cited fragmentation range to the 40.1 million acres of potentially affected environment. The agency should do that. A cited finding that is never applied to the affected acreage is not a finding, it is a footnote used as insulation. I ask that the agency apply the cited fragmentation range to the 40.1 million acres of potentially affected environment and explain on the record what that projection means for the species the document identifies as sensitive to road presence. On the question of economics: 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 supporting analysis reaches its no-impact conclusion by spreading expenditure losses across every small firm in the sector nationally rather than looking at the outfitters and guides who actually hold permits in the affected areas. I have spent time in many national forests throughout the years and have seen how staff manage these places using minimal resources, how infrastructure falls into disrepair because of personnel and budget constraints. The people guiding trips into these landscapes operate under the same constraints. Diluting their projected losses into a national average and calling the result no significant impact is not a defensible methodology. The agency should withdraw that certification and assess the impact on the small entities actually operating in the potentially affected roadless areas. The question of new roads compounds all of this. Let's take care of what already exists before we think of adding new roads. That is not sentiment, it is resource management. The agency has acknowledged a substantial maintenance backlog on its existing road system. Adding road miles into currently roadless country while that backlog persists does not represent a rational allocation of limited budget and personnel, and the DEIS does not explain how it would be one. The agency should answer that question before any final action is taken. Sincerely, J. Mothershed Georgia