Comment Analysis · Docket FS-2025-0001

FS-2025-0001-596003

Opposes rescissionA2 moderateSubstance 14/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment establishes that the agency's draft EIS contains internal contradictions regarding fire risk and economic benefits, and fails to provide necessary projections for water quality, biodiversity fragmentation, and big game populations across the 40.1 million acres affected by the proposed 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, Evidence.

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
    • “Mammals are what bring me into the backcountry”
    • “gray wolf, moose, Canada lynx, and black bear”
    • “habitat fragmentation reduces biodiversity by 13 to 75 percent”
    • “elk survival rates increased during a road closure”
  • Water Quality Quantity
    • “Water is the most integral resource for the entire world”
    • “378 municipal water intakes sit in watersheds containing affected roadless areas”
    • “roads and their facilities can produce up to 90 percent of the sediment”
    • “protecting headwaters that flow to both the Atlantic and the Gulf”
  • Economic Impact Fiscal
    • “The economics do not hold together either”
    • “timber revenue to the Forest Service of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year”
    • “agency is already $6.9 billion behind on maintaining the roads it has”
    • “A range that includes a $92 million loss does not establish a net benefit”
  • Forest Management Wildfire
    • “Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires”
    • “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
    • “The proposal moves toward more roads, not fewer, while citing fire risk as a driver”
    • “ignition density data reported in its own DEIS Table 21”

What it names

National Forests
Pisgah National ForestSuperior National Forest
Roadless areas
Harper CreekHegman LakesLinville Gorge AdditionLost CovePhantom LakeSouth Kawishiwi RiverWilson Creek

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Mammals are what bring me into the backcountry. I keep a species life list, and the roadless areas of Pisgah National Forest in North Carolina and Superior National Forest in Minnesota are places I go looking for them: gray wolf, moose, Canada lynx, and black bear in the Superior's lake country around Phantom Lake, Hegman Lakes, and the South Kawishiwi River; black bear and the more than 30 endemic salamander species of the Southern Appalachians in the hollows and gorges around Wilson Creek, Harper Creek, Lost Cove, and Linville Gorge Addition. The agency is now proposing to rescind the 2001 Roadless Area Conservation Rule, and I am filing this comment in opposition. The proposal uses wildfire and fuels management as part of its justification for rescission. The agency's own record states: "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." That finding is in the agency's draft environmental impact statement. The proposal moves toward more roads, not fewer, while citing fire risk as a driver. I ask that the agency explain, with specificity, why this proposal departs from its own prior findings on fire occurrence inside roadless areas, and that it reconcile the rescission with the ignition density data reported in its own DEIS Table 21, which shows far higher fire density on roaded land. The economics do not hold together either. The agency's own record states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." I work hard and the government takes my money, and I want it going to things that actually benefit me and my community. The agency's own cost-benefit analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. A range that includes a $92 million loss does not establish a net benefit. Meanwhile the agency is already $6.9 billion behind on maintaining the roads it has, against a road budget of approximately $73 million a year. The agency must reconcile its proposal with those figures and explain how opening 40.1 million acres to new road construction serves the public when the maintenance backlog already overwhelms what the agency can afford. Water is the most integral resource for the entire world. If we destroy it, we destroy ourselves. Across the Southern region alone, which includes North Carolina, 378 municipal water intakes sit in watersheds containing affected roadless areas, and the agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale. The Pisgah holds 18 inventoried roadless areas totaling 99,369 acres protecting headwaters that flow to both the Atlantic and the Gulf. Fewer than 12 percent of those watersheds have impaired streams today. The agency has not explained how it proposes to keep that number from rising once road construction is permitted in areas currently protected. The agency must answer that question directly. The agency's own DEIS cites the finding that "habitat fragmentation reduces biodiversity by 13 to 75 percent." That range appears in the document and then goes nowhere. No projection across the 40.1 million acres of potentially affected environment follows from it. The Southern Appalachians where I look for mammals are among the most biodiverse temperate forests in North America, and the Superior's roadless areas are the hydrological engine of the entire Boundary Waters Canoe Area Wilderness system. The agency must apply the cited fragmentation range to the 40.1 million acres of potentially affected environment and show what that means for the species verified to live there. Finally, the agency's 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." That finding, like the fragmentation data, appears and is then left unresolved. No population-level projection for big game follows anywhere in the document. The agency must project what the proposed rescission means for big game populations and for the hunting opportunity that depends on them, and it must do so before this rulemaking advances further. Sincerely, Taylor Apel Ely, MN

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