Comment Analysis · Docket FS-2025-0001

FS-2025-0001-608401

Opposes rescissionA2 moderateSubstance 12/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents that the DEIS cites specific scientific findings regarding bird abundance, habitat fragmentation, and carbon storage, as well as its own biological assessment of adverse effects on 327 ESA-listed species, but fails to project these impacts across the 40.1 million acres of potentially affected environment or provide mitigation strategies.

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
- “bird richness declines with road presence”
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
- “jaguars documented crossing from Mexico”
- “Mexican spotted owl, Gould's turkey, Arizona treefrog, and ocelot”
Climate Carbon Storage
- “inventoried roadless areas contain about 5 percent of the stored forest carbon”
- “roughly 0.9 billion metric tons”
- “quantify the change in carbon storage and sequestration”
Scientific Research Evidence
- “agency's own cited science”
- “Kroeger et al. 2022; McClure et al. 2013; Ware et al.”
- “follow its own evidence to its own conclusions”
Recreation Tourism Public Use
- “Chiricahuas offer peaceful solitude”
- “I hike the Santa Rita Mountains frequently”
- “responsible recreation”

What it names

National Forests: Coronado National Forest
Roadless areas: Santa Rita
Works cited: Kroeger et al. 2022

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Chiricahuas offer peaceful solitude, and the Santa Ritas feel like a whole other world, so close to Tucson yet entirely apart from it. I hike the Santa Rita Mountains frequently, looking for birds like elegant trogons found only in the sky islands of Arizona. These are not generic public lands to me. They are the reason I go outside. Rescinding the 2001 Roadless Area Conservation Rule would damage exactly what I am looking for when I go there, and this comment asks the agency to answer, specifically, for what its own documents already say. The Coronado National Forest holds 23 inventoried roadless areas totaling 482,687 acres, spanning the Santa Ritas, Chiricahuas, Galiuros, and Rincons, the connective tissue between the sky island ranges. Each range is an island of cool forest in a sea of hot desert. The birds I look for depend on that structure. The DEIS cites the finding 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. (Kroeger et al. 2022; McClure et al. 2013; Ware et al.) That is what the agency's own cited science says will happen to the habitat I walk through in the Santa Ritas. What I want to know is why that finding appears in the document and then disappears, with no projection of what it means for bird populations across the affected areas, and I ask the agency to address that gap directly. The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. That range appears once and is then set aside. No projection across the 40.1 million acres of potentially affected environment follows from it. Arizona holds 78 inventoried roadless areas totaling 1,174,256 acres. The trogons I hike to see, the jaguars documented crossing from Mexico through the Santa Ritas into the Rincon Mountains and beyond, the verified species of the Coronado sky islands including Mexican spotted owl, Gould's turkey, Arizona treefrog, and ocelot: all of them live within a landscape whose integrity is measured partly by that fragmentation range. I ask that the agency apply the cited fragmentation range to the 40.1 million acres of potentially affected environment and explain what that means for the species already documented there. The agency's own biological assessment does not soften its conclusion. "Rescinding the 2001 Roadless Rule will increase the likelihood of road construction and timber harvests occurring in locations previously considered inventoried roadless areas. In many cases the Forest Service anticipates this increased activity to adversely affect some ESA-listed species and their designated critical habitats." The DEIS tallies the determinations: "may affect, likely to adversely affect" for 327 ESA-listed species and 71 designated critical habitats. That is the agency's own count, from the agency's own assessment. The proposal identifies mitigation for none of it. I ask that the agency disclose, species by species, how the likely adverse effects its own biological assessments identify will be avoided or mitigated, and that ESA consultation be completed and published before any final rule is issued. The DEIS cites the estimate that these inventoried roadless areas contain about 5 percent of the stored forest carbon in the coterminous United States, roughly 0.9 billion metric tons. That number is stated and then left alone. No analysis of what harvest and roading would release under each alternative follows from it. Our public lands should be managed for wildlife, habitat, and responsible recreation, and none of those purposes is served by a document that cites a carbon figure of that scale and then draws no conclusions from it. The agency should quantify the change in carbon storage and sequestration under each alternative. The Santa Ritas are special because they are still intact. That is not sentiment; it is what the agency's own cited science describes when it documents the relationship between roads, noise, fragmentation, and biological loss. I am asking the agency to follow its own evidence to its own conclusions before it acts. Sincerely, Alex Patia Tucson, AZ