Comment Analysis · Docket FS-2025-0001

FS-2025-0001-600662

Opposes rescissionA3 weakSubstance 9/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents that the DEIS fails to project the cited 13-75% biodiversity reduction from habitat fragmentation across the 40.1 million acres of potentially affected environment, and requests that the agency complete this analysis before finalizing the rescission of the Roadless Area Conservation Rule.

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

A3 weak: Substantive, but easier to set aside.

Owed an answer on Analytical gap.

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
- “bird richness declines with road presence”
- “road-noise experiments... cut bird abundance by over a quarter”
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
Recreation Tourism Public Use
- “hikers and birdwatchers”
- “value the peace and quiet of no roads”
- “silence itself is the habitat”
Environmental Protection Biodiversity
- “The biodiversity is amazing”
- “fragmentation reduces biodiversity”
- “apply the cited fragmentation range to those 40.1 million acres”

What it names

National Forests: Wasatch-Cache National Forest

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 My husband and I are hikers and birdwatchers, and the best birdwatching, in our experience, is sitting in a quiet forest in a spot you have hiked to reach. The biodiversity is amazing. That is why the proposed rescission of the 2001 Roadless Area Conservation Rule troubles me deeply. I live near the Wasatch-Cache National Forest, and the roadless area of Mt. Olympus encompasses 9,982 acres of it. We have hiked a portion of that forest and value the peace and quiet of no roads. What is at stake here is not abstract to me. The birds are the reason my husband and I seek out quiet forest. The DEIS cites the findings 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. Those findings apply directly to the kind of birdwatching we do in the Wasatch-Cache, where the silence itself is the habitat. The DEIS also states: "The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent." That range is striking, and it appears in the record without any projection across the 40.1 million acres of potentially affected environment. I ask that the agency apply the cited fragmentation range to those 40.1 million acres before finalizing any decision, so that the public and the decision-makers can see what the numbers actually mean at scale. The forest my husband and I walk into above Salt Lake City is quiet because it has no roads. That quiet is what makes the birds findable and the biodiversity visible. The agency's own citations confirm that roads reduce richness, fragment habitat, and cost the treasury more than they return. The record contains the facts needed to reach a defensible conclusion. What it lacks is the work of applying those facts to the decision being made. I oppose the rescission and urge the agency to complete that analysis before proceeding. Sincerely, Lenora Olson Salt Lake City, UtahRe: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001