Comment Analysis · Docket FS-2025-0001

FS-2025-0001-604724

Opposes rescissionA2 moderateSubstance 13/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents the commenter's professional and personal standing in stream restoration and public lands use, and places on the record specific deficiencies in the agency's DEIS regarding the conflict between road construction and wildfire risk (citing DEIS Table 21), the negative economic net present value of the proposal, and the impact on biodiversity in specific roadless areas like Pisgah National Forest.

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

Water Quality Quantity
- “damage to intact headwater systems is expensive and irreversible”
- “erosion and sedimentation cost counties, states, tribes, landowners, federal agencies, and taxpayers”
- “protecting the last unfragmented headwaters”
- “sustaining ecosystem services including clean air and water”
Wildlife Habitat
- “habitat for cerulean warblers, northern long-eared bats, hellbenders, brook trout, and more than 30 endemic salamander species”
- “bird richness declines with road presence in forested habitat”
- “protecting habitat for rare and listed species, reducing habitat fragmentation”
- “degradation of the last contiguous habitats protecting many listed and rare species”
Climate Carbon Storage
- “twin crises of climate change and biodiversity loss”
- “Public lands should be managed to promote biodiversity and climate resiliency”
- “hold the key to our shared future on Earth”
Recreation Tourism Public Use
- “I often travel to natural areas to watch birds, recreate, and find peace”
- “recreation losses of at least $6.1 million a year”
- “I want these places preserved and protected for other visitors and future generations”

What it names

National Forests: Allegheny National Forest Pisgah National Forest

The comment

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

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. My career in stream restoration has taught me something that seems lost on the agency proposing this rescission: damage to intact headwater systems is expensive and irreversible. I have had to seek federal funding to restore streams in urban and rural landscapes, including Cuyahoga Valley National Park. I know what erosion and sedimentation cost counties, states, tribes, landowners, federal agencies, and taxpayers long after the roads that caused them have served their purpose. Opening new roads into the roadless areas that protect the last unfragmented headwaters strikes me not as management but as the deliberate manufacture of future problems. These areas are a national treasure and hold the key to our shared future on Earth, in the context of our twin crises of climate change and biodiversity loss. I often travel to natural areas to watch birds, recreate, and find peace. I have hiked and worked across public lands in Utah, Idaho, Nevada, California, Oregon, and Washington since 2004. Annually, my family travels from Ohio to Allegheny National Forest and Pisgah National Forest to hike and bike. The 18 inventoried roadless areas of Pisgah, totaling 99,369 acres, include headwaters of the Atlantic and the Gulf, habitat for cerulean warblers, northern long-eared bats, hellbenders, brook trout, and more than 30 endemic salamander species found nowhere else on Earth. The agency's own record acknowledges 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. The agency has this finding in its own DEIS and has chosen not to treat it as decisive. I ask the agency to explain how that finding is outweighed by the justifications offered for rescission. Public lands should be managed to promote biodiversity and climate resiliency, protecting habitat for rare and listed species, reducing habitat fragmentation, and sustaining ecosystem services including clean air and water. The Pisgah and Nantahala roadless areas, combined with Utah's 4,013,529 acres across 222 inventoried roadless areas and the lands I have walked in six western states, represent the core of what remains of unfragmented forested habitat at national scale. Rescinding the 2001 rule trades that permanence for benefits the agency's own cost-benefit analysis cannot confirm. I ask the agency to reconcile the proposal with its own economic analysis, which projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million, and to explain how an action whose own analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog. My tax dollars should support conservation and habitat protection, not the degradation of the last contiguous habitats protecting many listed and rare species. The wildfire rationale offered for this rescission sits in direct tension with the agency's own findings. The DEIS 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." Our western forests need adequate management to reduce the risk of widespread wildfire, and I support that goal, but deforestation is not the answer and neither is a road network that, by the agency's own data, elevates ignition risk. The agency must explain why the proposal departs from these findings and reconcile the rescission with DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. I commented on this rescission in 2025 and received no response. I feel that legislators are not listening to or representing the interests of their constituents and are bowing to corporate interests aimed at gutting our shared natural resources. I want these places preserved and protected for other visitors and future generations. This docket deserves an answer to each of the points raised above. Sincerely, Ann Gilmore, Kent, Ohio 44240