Comment Analysis · Docket FS-2025-0001

FS-2025-0001-591925

Opposes rescissionA2 moderateSubstance 9/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment documents specific opposition to the rescission of the Roadless Area Conservation Rule, citing the unique status of Mogan Ridge in Indiana, the DEIS's own findings on habitat fragmentation and increased costs, and the procedural deficiency of a curtailed public comment period compared to the 2001 rulemaking.

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

Recreation Tourism Public Use
- “value the roadless areas... for quiet, remote and self-reliant recreation”
- “tragic loss of wild lands”
- “economic impact on the many businesses, such as outfitters and guide services”
Water Quality Quantity
- “Roads alter watershed hydrology and stream channels”
- “negatively impact fish such as trout and salmon which are dependent on cold, clean water”
- “removing protections from these lands puts their water quality at risk”
Environmental Protection Biodiversity
- “impact on habitat for birds, fish, and other wildlife”
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
- “extirpation or fragmentation of their populations”
Governance Policy Process
- “no public meetings and a sharply curtailed public comment period”
- “wishes to avoid the negative publicity”
- “Every conservation alternative was eliminated for failing that purpose”

What it names

National Forests: Hoosier National Forest
Roadless areas: Mogan Ridge

The comment

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

I strongly oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. As a resident of south-central Indiana, there are few pristine natural environments left within easy reach of me, and there few throughout the entire midwest. Mogan Ridge in the Hoosier National Forest is the only inventoried roadless area in the state of Indiana, and rescinding the Roadless Area Conservation Rule will put it at risk.. As an avid hiker, camper, fisherman and amateur photographer, I frequently use National Forests lands both in the midwest and throughout the country, frequently visiting these wild lands in both the eastern and western U.S. I value the roadless areas that are placed at risk by the proposed rescission for quiet, remote and self-reliant recreation. There are thousands of miles of trails inside the affected areas and under rescission these areas could shift toward more developed conditions, which would be a tragic loss of wild lands. As a trout angler, I recognize that many of the waters that I fish in originate in these roadless areas. Roads alter watershed hydrology and stream channels. Sedimentation from harvest, and from roads and their skid trails, can promote excessive substrate movement and negatively impact fish such as trout and salmon which are dependent on cold, clean water. The clean water that flows from the impacted roadless lands are the reason why we still have cold-water fisheries in the U.S. today. In addition, millions of Americans depend on the waters that originate in these roadless areas as the eventual source of their drinking water, and removing protections from these lands puts their water quality at risk. Rescission of the roadless rule will have an economic impact on the many businesses, such as outfitters and guide services, that depend on outdoor recreation such as hunting, fishing, hiking and camping. In many states, the outdoor recreation industry far oustrips extractive industries in impact on the local economy. These areas are the last unroaded parts of the national forests, and the Draft Environmental Impact Statement (DEIS) is explicit about the impact on habitat for birds, fish, and other wildlife. The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent, and in its own words on wide-ranging mammals like the grizzly: they “have suffered habitat loss and the extirpation or fragmentation of their populations.” In the DEIS’s own comparison, the rescission alternative “has the greatest potential for negative effects to scenery.” The stated purpose of the rescission of the Roadless Rule is NOT to promote forest health. The purpose and need is to supposedly reduce regulatory burden on the Forest Service. Every conservation alternative was eliminated for failing that purpose. In its own words, the agency states “This proposed rescission does not mandate timber cutting or road construction.” Nothing about management is promised, only the removal of protections. The last unroaded third of the national forests is at stake with this proposed change. The 2001 rule was written through more than 600 public meetings and more than 1.6 million public comments, yet this proposed rescission has been the subject of no public meetings and a sharply curtailed public comment period. One suspects that the agency understands that this proposed rescission is extremely unpopular and wishes to avoid the negative publicity that such public meetings and comments would generate. Further, this cannot possibly be portrayed as a cost-saving measure for the Forest Service. Road appropriations have fallen from $234 million to $73 million between 2004 and 2024. The DEIS states outright that road mileage, maintenance and management costs are likely to increase. Finally, the rescission of the Roadless Rule will not decrease the number and frequency of wildfires. Human-caused ignitions, the prevalent cause of wildfires in our national forests, occur most frequently around roads, not in roadless areas. In summary, I strongly oppose the proposed rescission of the Roadless Area Conservation Rule. These lands must be protected for the security and enjoyment of future generations.