Comment Analysis · Docket FS-2025-0001

FS-2025-0001-605792

Opposes rescissionA1 strongSubstance 12/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents specific deficiencies in the DEIS regarding the lack of site-specific projections for sediment delivery, drinking water protection, and habitat fragmentation, while highlighting a contradiction between the small-business certification and the DEIS's own economic analysis of lost recreation benefits.

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

A1 strong: Must be answered — it names the law.

Owed an answer on Analytical gap, Legal.

Standard dismissals it defeats

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.
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.
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.

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.
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.

Topics

Water Quality Quantity
- “Road sediment is quantified and then set aside”
- “24 million people's drinking water is asserted away”
- “clean gravel and clear current are what make them fishable”
- “quantify projected sediment delivery to the more than 7,000 municipal intakes”
Environmental Protection Biodiversity
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
- “Good fishing depends on intact, connected watersheds, not fragments”
- “apply the cited fragmentation range to the 40.1 million acres”
- “effects of the road construction and timber harvest it would newly allow”
Recreation Tourism Public Use
- “traveling to hike and camp with my family for more than 30 years”
- “I love seeing wildlife”
- “small outfitters and guides who work this same country help people like me get out there”
- “lost recreation benefit at a minimum of $6.1 million a year”
Governance Policy Process
- “I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule”
- “ask that the agency disclose and analyze the site-specific environmental consequences”
- “analyze in the DEIS an alternative that retains the 2001 rule's protections”
- “provide a reasoned explanation for it on the record”

What it names

National Forests: Ocala National Forest
Law cited: 36 CFR 294.12

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I have been traveling to hike and camp with my family for more than 30 years. We've driven from Florida to Wyoming more than once to enjoy a type of nature we don't have: old forests on mountains. We've been to California to see the redwoods, and Utah for the stone formations I love seeing wildlife. Being able to see bears or wolves in their natural habitat is an incredible privilege. Checking off a bird species that you can't see anywhere else from your life list is an unbelievable accomplishment. These are PUBLIC lands and they should be managed for the public. That means not selling them off and not carving out patches for the enrichment of private companies. It means smart management practices that won't increase the probability of fires, which the addition of roads will do, per the government's own study. I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule, and specifically about Ocala National Forest (4,855 acres), Ocala National Forest National Forest, Florida. I ask that the agency disclose and analyze the site-specific environmental consequences of the proposed rescission for each of these areas, including the effects of the road construction and timber harvest it would newly allow. I raise the following issues for the record and ask that the agency respond to each of them: Issue 1: Road sediment is quantified and then set aside I fish these waters, and clean gravel and clear current are what make them fishable. What roads send downstream lands on the fish first, and on me right after. The DEIS: skid roads, trails, log landings and similar disturbances within timber sale areas are the main cause of soil erosion and "can contribute up to 90 percent of the sediment generated by timber sale activity." The number appears in the document; no projection of sediment delivery follows it. I ask that the agency quantify projected sediment delivery to the more than 7,000 municipal intakes downstream of these areas. Issue 2: Twenty-four million people's drinking water is asserted away As an angler I am on this water regularly, and the water I fish is the same water communities drink. What happens in the headwaters reaches all of us downstream. Approximately 24 million people use water originating within the potentially affected roadless areas, through more than 7,000 municipal intakes, and less than 12 percent of these watersheds are currently impaired. The DEIS says forest plans address sources of public drinking water without identifying one enforceable provision. I ask that the agency identify, forest by forest, which plan provisions are equivalent to 36 CFR 294.12 and 294.13 for municipal watersheds. Issue 3: Fragmentation is quantified and not applied Good fishing depends on intact, connected watersheds, not fragments. I fish, and I raise this because the agency quantified fragmentation and then never applied it. The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. The number appears; no projection across the 40.1 million affected acres follows. I ask that the agency apply the cited fragmentation range to the 40.1 million acres of potentially affected environment. Issue 4: The small-business certification contradicts the analysis beside it I hike and camp in these areas, and the small outfitters and guides who work this same country help people like me get out there. They deserve a real assessment. The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. The supporting regulatory flexibility analysis reaches its no-impact conclusion by spreading the $9 million annual expenditure loss across every small firm in the sector nationally, rather than assessing the outfitters and guides actually holding permits in the affected areas, and concedes some firms may lose these receipts. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule's protections for the areas named above. Where this proposal rests on factual conclusions that differ from the agency's own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record. Sincerely, Kellie Chan Chuluota, FL