Comment Analysis · Docket FS-2025-0001

FS-2025-0001-608570

Opposes rescissionA0 noneSubstance 3/24Posted October 7, 2026 On Regulations.gov

Small family — One letter sent by 3 to 9 people, copied or lightly reworded. One of 3 submissions in its group; the sender added words of their own. See the letter, its submissions and topics.

Carries the letter's score — A copy of a family's letter; it holds the score and answerability level of the letter it sent.

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. This rating is the one its shared letter earned.

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
    • “preserving the diversity of plant and animal species”
    • “direct habitat loss, habitat degradation through increased isolation”
    • “308 species (57%) have at least some suitable habitat in one or more inventoried roadless areas”
  • Environmental Protection Biodiversity
    • “loss of regional connectivity and biodiversity”
    • “degraded ecosystems over time”
    • “invasion by disturbance-adapted species”
  • Scientific Research Evidence
    • “peer-reviewed research demonstrates”
    • “Watson et al. find that”
    • “Dietz et al. find that”

What it names

Works cited
10.1016/j.gecco.2021.e0194310.1038/s41559-018-0490-x

The comment

I am a student studying environmental science/biology/forestry and I am concerned about the environmental impacts of road construction in forests currently protected by the Roadless Rule I strongly support the No Action alternative (Alternative 1) in the current Draft Environmental Impact Statement. While the proposed rescission claims to address conservation objectives such as preserving the diversity of plant and animal species, peer-reviewed research demonstrates that removing Inventoried Roadless Area (IRA) protections will directly contradict this objective. For example, Watson et al. find that “There is a direct correlation between the risk of species extinction and human footprint. Impacts such as direct habitat loss, habitat degradation through increased isolation of plant and animal populations, greater exposure to edge effects, and invasion by disturbance-adapted species are cumulative, leading to degraded ecosystems over time and, eventually, loss of regional connectivity and biodiversity” (doi.org/10.1038/s41559-018-0490-x). Additionally, Dietz et al. find that, “Of the 537 wildlife species of conservation concern in the contiguous United States, 308 species (57%) have at least some suitable habitat in one or more inventoried roadless areas. Despite their geographic and elevational clustering and predominance of a single biome type, IRAs provide a larger proportion of suitable habitat for multiple wildlife SCCs than non-IRA lands. If all IRAs were added to the protected-area system, there would be a substantial decrease (−38) in the number of wildlife SCCs that are currently considered 'poorly represented' in protected areas.” (doi.org/10.1016/j.gecco.2021.e01943) As an outdoor scientist / concerned student / person who cares about nature, I urge the USDA to maintain 2001 Roadless Area Conservation Rule protections in full. -Concerned citizen

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