Comment Analysis · Docket FS-2025-0001

FS-2025-0001-586808

Opposes rescissionA2 moderateSubstance 12/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment documents that the agency's DEIS fails to apply cited fragmentation and fire risk data to the specific 40.1 million acres and Kentucky's roadless areas, and requests an accounting of downstream water costs and big game projections before finalizing the rescission.

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
- “protects headwater streams”
- “bird richness declines with road presence”
- “shelters over 5,000 Virginia big-eared bats”
- “elk survival rates increased during a road closure”
Water Quality Quantity
- “7,000 municipal water intakes sit in watersheds fed by roadless areas”
- “roads and their facilities can produce up to 90 percent of the sediment”
- “Fewer than 12 percent of those watersheds have impaired streams today”
- “if these watersheds are polluted, the costs of remediation will far exceed”
Environmental Protection Biodiversity
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
- “31 percent of species avoiding the noise entirely”
- “federally endangered species”
- “incrementally erode nationally significant roadless values”
Recreation Tourism Public Use
- “Bird watching is good for my brain health”
- “I do not want to lose that access”
- “look for pileated woodpeckers in Daniel Boone National Forest”
- “quiet, remote, and backcountry recreation values”

What it names

National Forests: Daniel Boone National Forest
Roadless areas: Wolfpen

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Bird watching is good for my brain health, and I have access to look for pileated woodpeckers in Daniel Boone National Forest. I do not want to lose that access. This comment opposes the proposed rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001). Daniel Boone National Forest holds Kentucky's entire roadless inventory: the Wolfpen roadless area, at 2,835 acres, protects headwater streams feeding the Red River, Kentucky's only National Wild and Scenic River. The DEIS cites the finding 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. That finding describes exactly what is at stake for the birds I go to Daniel Boone to find. The forest also shelters over 5,000 Virginia big-eared bats in the deep sandstone overhangs of the Red River Gorge, roughly 40 percent of the global population of a federally endangered species, along with the Indiana bat, Kentucky arrow darter, blackside dace, and northern long-eared bat. Rescinding the rule removes the principal protection for all of it. I ask that the agency explain how the rescission accounts for documented impacts on bird communities and sensitive species in the one inventoried roadless area in Kentucky. The agency's own record says: "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." The roads we already have need to be maintained and used for their intended purpose, including forest fire prevention. It makes no sense to build new roads on public land for purposes that do not serve the public when the agency's own findings show that doing so raises fire risk. I ask that the agency explain why this proposal departs from its own prior findings on fire occurrence and reconcile the rescission with the ignition data in its own draft environmental impact statement. The agency has been down this path before. The record contains the agency's own statement that "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." A state-by-state approach was attempted and its deficiencies were identified in prior litigation. The agency should explain how this proposal avoids those same deficiencies and address its own prior finding that local decision-making can incrementally erode nationally significant roadless values. If something is not broken, why is the government trying to break it? The agency's own DEIS states: "The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent." That range is cited and then not applied to the 40.1 million acres of potentially affected environment. A range that wide, left unanalyzed across the full affected acreage, is not an adequate basis for a decision of this magnitude. The agency must apply that cited fragmentation range to the full 40.1 million acres and disclose the results before finalizing any rescission. On water, the math points in one direction. More than 7,000 municipal water intakes sit in watersheds fed by roadless areas, and the agency's own analysis indicates that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Fewer than 12 percent of those watersheds have impaired streams today. Water is life, and if these watersheds are polluted, the costs of remediation will far exceed whatever the logging industry stands to gain. It sounds like the public will be spending significantly more money than the logging industry will make. The agency has not presented a credible accounting of those downstream costs, and I ask that it do so. Finally, the agency's own record states: "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." No population-level projection for big game or hunter opportunity appears anywhere in the document. The agency should project those effects before proceeding. Sincerely, Emily Dahl Louisville, KY