Comment Analysis · Docket FS-2025-0001

FS-2025-0001-578138

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

In short: The comment documents that the DEIS and draft biological assessment cite specific scientific findings regarding bird abundance, habitat fragmentation, and elk survival, as well as anticipated adverse effects on 327 ESA-listed species, but fail to apply these findings to the 40.1 million acres affected, project population-level impacts on big game, or provide mitigation strategies for the identified harms.

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
- “bird richness declines with road presence”
- “habitat fragmentation reduces biodiversity”
- “elk avoid roads and select unroaded habitat”
- “adversely affect some ESA-listed species”
Environmental Protection Biodiversity
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
- “road-noise experiments... cut bird abundance”
- “31 percent of species avoiding the noise entirely”
- “71 designated critical habitats”
Recreation Tourism Public Use
- “enjoy the quiet, solitude, beautiful scenery”
- “wildlife watching is an economic boost”
- “reduced hunting success due to a fragmented landscape”
- “economic incentive it brings to our community”
Legal Regulatory Framework
- “ESA consultation be completed and published”
- “disclose, species by species, how the likely adverse effects... will be avoided or mitigated”
- “DEIS does not consider how the rescinding... would impact such economies”
- “apply that fragmentation range to the 40.1 million acres”

What it names

National Forests: Bighorn National Forest

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequestLegal

Dear Secretary Rollins, I strongly oppose the full or partial rescinding of the Roadless Rule. I am a wildlife professional who lives near the Bighorn National Forest and this ruling negatively affects me and my community. When I visit the Bighorn National Forest, I enjoy the quiet, solitude, beautiful scenery, especially around Powder River Pass. I love to go birding in the forests and look for nesting birds and raptors like goshawks and warblers. That pursuit depends entirely on habitat that roads would degrade. The DEIS does not ignore this. It 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. The agency has this science in hand and is moving forward anyway. I want to know how the agency reconciles that evidence with a proposal that will expand road construction into inventoried roadless areas, and I ask for a clear answer in the record. The agency's own document also states: "The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent." That range appears in the text and then disappears. No projection follows. The 40.1 million acres potentially affected by this rescission are never run through that calculation. A finding that broad cannot simply be cited and abandoned. I ask that the agency apply that fragmentation range to the 40.1 million acres of potentially affected environment and explain what the resulting biodiversity loss would look like. Additionally, wildlife watching is an economic boost to our local community around the Bighorn National Forest, and the DEIS does not consider how the rescinding of the rule would impact such economies from reduced wildlife presence. The document also contains this: "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." The agency cites this finding about elk and roads and then produces no population-level projection anywhere in the analysis. Hunters and wildlife managers need to know what this proposal means for big game. I ask that the agency project the effects on big game populations and hunter opportunity before this rule is finalized. This has a significant impact in my local area for myself as an elk hunter and for the economic incentive it brings to our community. The DEIS does not address economic impacts from the rescinding of the rule would have on reduced hunting success due to a fragmented landscape. The most serious problem is this. 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 wrote that. The agency anticipates the harm. The proposal identifies mitigation for none of 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 is issued. I want to see economic analyses provided for a reduction in wildlife species in local economies, a better endangered species analysis review, and how the issue of habitat fragmentation would be mitigated. Thank you for your consideration of my comment