Comment Analysis · Docket FS-2025-0001

FS-2025-0001-591426

Opposes rescissionA0 noneSubstance 8/24Posted October 6, 2026 On Regulations.gov

In short: The comment places on the record that rescinding the Roadless Area Conservation Rule in the Chequamegon-Nicolet National Forest would harm migratory bird habitats, increase wildfire risk near roads, and impose an unaffordable $8.4 billion maintenance backlog on the federal government.

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

A0 none: Counted, not answered.

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.
Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
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.
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.

Topics

Wildlife Habitat
- “preserved irreplaceable habitat”
- “quiet, unfragmented habitat that many birds need”
- “forest fragmentation increases nest predation and cowbird parasitism”
Water Quality Quantity
- “protected sources of clean water”
- “located in source areas for many important rivers”
- “largest source of municipal water supply in the Nation”
Economic Impact Fiscal
- “rescinding the Roadless Rule is fiscally irresponsible”
- “estimated an $8.4 Billion maintenance backlog”
- “prevent the Federal Government from spending taxpayers' money”
Forest Management Wildfire
- “increasing road building will increase wildfires”
- “reduced the U.S. Forest Service workforce by 16%”
- “staff members played a role in mitigating wildfire”

What it names

National Forests: Chequamegon-Nicolet National Forest
Works cited: 10.1186/s42408-026-00450-2

The comment

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

We are residents of Wisconsin where the Chequamegon-Nicolet National Forest covers over 1.5 million acres in the northern part of our state. We strongly oppose the plans to rescind the Roadless Area Conservation Rule. This rule has protected our national forests, preserved irreplaceable habitat, and protected sources of clean water. Roadless areas provide the quiet, unfragmented habitat that many birds need, including the Kentucky Warbler, Louisiana Water Thrush, Ovenbird, Scarlet Tanager, and Wood thrush. A foundational study by the U.S. Forest Service found that forest fragmentation increases nest predation and cowbird parasitism. In fragmented zones, reproductive rates drop so low that populations become "sinks"—relying entirely on immigration from unfragmented source areas to survive. (Robinson, Scott K.; Thompson III, Frank R.; Donovan, Therese M.; Whitehead, Donald R.; Faaborg, John. 1995. Regional Forest Fragmentation and the Nesting Success of Migratory Birds. Science. Vol. 267 no. 5206.:p. 1987-1990.) ‘Water Facts’ published by the US Forest Service states that the US National Forest Service lands are located in source areas for many important rivers as well as local and regional aquifer systems. They are the largest source of municipal water supply in the Nation, serving over 60 million people in 3,400 communities in 33 States. Peer-reviewed evidence shows that increasing road building will increase wildfires (Aplet, G.H., Hartger, P. & Dietz, M.S. Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. fire ecol 22, 8 (2026). https://doi.org/10.1186/s42408-026-00450-2). If the Administration was serious about addressing wildfires, why did they reduce the U.S. Forest Service workforce by 16%? Many of those staff members played a role in mitigating wildfire and responding to wildfires. Additionally, rescinding the Roadless Rule is fiscally irresponsible. We already have 370,000 miles of roads in our National Forests. In 2000, the U.S. Forest Service estimated an $8.4 Billion maintenance backlog! Keep the Roadless Rule intact to prevent the Federal Government from spending taxpayers’ money on adding more roads to a system we don’t need and can’t afford.