Comment Analysis · Docket FS-2025-0001

FS-2025-0001-604690

Opposes rescissionA0 noneSubstance 5/24Posted October 7, 2026 On Regulations.gov

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

  • Environmental Protection Biodiversity
    • “fragment habitat, introduce disturbance, and eliminate roadless character”
    • “Roadless areas function as intact reference landscapes”
    • “retain levels of ecological integrity that roaded landscapes have lost”
    • “protect the last of these natural areas that we have left”
  • Water Quality Quantity
    • “Watersheds with the highest ecological integrity scores tend to have high proportions of roadless or wilderness area”
    • “watersheds with the lowest integrity tend to have low proportions of roadless area and high proportions of moderate-density roads”
  • Scientific Research Evidence
    • “USDA Forest Service, 2000”
    • “Talty et al., 2020”
    • “Belote, 2020”

What it names

National Forests
Chequamegon-Nicolet National Forest
Roadless areas
09186 - Shelp Lake
Works cited
10.1111/csp2.288

The comment

Dear Secretary: For someone who has spent enough time outdoors to know what happens after road access opens in an area, the 2001 Rule reads as a hard-won, practically-grounded protection — not a regulatory formality. Regarding the 09186 - Shelp Lake in the Chequamegon-Nicolet National Forest, Wisconsin: New road construction, reconstruction, and associated development fragment habitat, introduce disturbance, and eliminate roadless character. Roadless areas function as intact reference landscapes. Roadless areas retain levels of ecological integrity that roaded landscapes have lost. Watersheds with the highest ecological integrity scores tend to have high proportions of roadless or wilderness area (over 50 percent); watersheds with the lowest integrity tend to have low proportions of roadless area and high proportions of moderate-density roads (USDA Forest Service 2000; Talty et al. 2020). — USDA Forest Service, 2000 (https://www.fs.usda.gov/sites/default/files/roadless/roadless-feis-volume1.pdf); Talty et al., 2020 (https://doi.org/10.1111/csp2.288); Belote, 2020 (https://doi.org/10.1111/csp2.288) Rescinding the Roadless Rule would open the 09186 - Shelp Lake, Chequamegon-Nicolet National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. Rescission of this rule would be a major step back for our country. It is very important that we protect the last of these natural areas that we have left. Stand by the Rule. Faithfully, CommentID: RLC-20261007-VTYAA6

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