Comment Analysis · Docket FS-2025-0001

FS-2025-0001-586831

Opposes rescissionA1 strongSubstance 15/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment establishes that the DEIS fails to quantify sediment delivery to municipal intakes, identify specific forest plan provisions equivalent to 36 CFR 294.12/294.13, apply fragmentation data to the 40.1 million acres of affected environment, or properly analyze impacts on local small entities, thereby documenting specific analytical gaps in the record.

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
- “skid roads... are the main cause of soil erosion”
- “quantify projected sediment delivery to the more than 7,000 municipal intakes”
- “24 million people use water originating within the potentially affected roadless areas”
- “identifies no enforceable provision in any plan that carries the equivalent protective force”
Environmental Protection Biodiversity
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
- “support wildlife that depends on the interior conditions that roadless designation preserves”
- “apply the cited fragmentation range to the 40.1 million acres of potentially affected environment”
Governance Policy Process
- “ask the agency to address the specific failures of analysis”
- “The agency cites the risk and walks away from the math”
- “The agency must withdraw the certification and perform the analysis on the small entities actually operating”
- “An assertion is not a substitute for a showing”
Recreation Tourism Public Use
- “DEIS names outfitters, guides and tour operators as affected”
- “books lost recreation benefit at a minimum of $6.1 million a year”
- “examining the outfitters and guides who actually hold permits in the affected areas”

What it names

National Forests: Allegheny National Forest George Washington National Forest
Roadless areas: Clarion RiverNorthern Massanutten
Law cited: 36 CFR 294.12

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Clarion River corridor in the Allegheny National Forest, the Northern Massanutten in George Washington National Forest, and Big Schloss along the Virginia and West Virginia border are places I care about, and the proposed rescission of the 2001 Roadless Area Conservation Rule threatens all three. I oppose this rescission and ask the agency to address the specific failures of analysis described below. The DEIS 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 striking and then abandoned. The document does not carry it forward into any projection of how much sediment would actually reach waterways downstream of the 3,821 acres at the Clarion River, the 9,444 acres at Northern Massanutten, or the 8,375 acres at Big Schloss, let alone downstream of affected roadless areas across the broader landscape. Pennsylvania alone holds 7 inventoried roadless areas totaling 24,866 acres, and across the Eastern region, which includes Pennsylvania, 286 municipal water intakes sit in watersheds containing affected roadless areas. The agency cites the risk and walks away from the math. I ask that the agency quantify projected sediment delivery to the more than 7,000 municipal intakes downstream of these areas before any final action is taken. On drinking water more broadly, the DEIS states 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. The agency then asserts that existing forest plans adequately protect those sources, but identifies no enforceable provision in any plan that carries the equivalent protective force of 36 CFR 294.12 and 294.13. An assertion is not a substitute for a showing. The agency must identify, forest by forest, which plan provisions perform the same protective function as those regulations for the municipal watersheds affected, and must do so with enough specificity that the public can evaluate the claim. The fragmentation analysis suffers the same pattern of citation without application. The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. That range, presented without qualification, is substantial. Yet no projection follows it across the 40.1 million acres of potentially affected environment. The places I have named, the Clarion River corridor among them, support wildlife that depends on the interior conditions that roadless designation preserves. A finding of that magnitude deserves more than a footnote. The agency should apply the cited fragmentation range to the 40.1 million acres of potentially affected environment and explain what the results mean for species within the affected landscape. The regulatory flexibility analysis compounds these problems by reaching a conclusion that cannot be reconciled with the document sitting beside it. 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 certification is achieved by spreading an annual expenditure loss across every small firm in the relevant sector nationally, diluting the impact to invisibility, rather than examining the outfitters and guides who actually hold permits in the affected areas. The DEIS concedes some firms may lose these receipts. That concession alone should have triggered a harder look. The agency must withdraw the certification and perform the analysis on the small entities actually operating in and around the potentially affected roadless areas, not on the average national firm in a category. These are not peripheral objections. Each involves a number the agency chose to include and then declined to use. The Clarion River corridor, Northern Massanutten, and Big Schloss deserve an analysis equal to what the agency's own data makes possible. I urge the agency to address each of these points in the record and to maintain the 2001 rule. Sincerely, Maurice E Chioda Dallastown, PA