Comment Analysis · Docket FS-2025-0001

FS-2025-0001-608700

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

In short: The comment establishes that roadless areas in the Chiricahuas and Sky Island ranges are critical for the habitat connectivity and population viability of wide-ranging threatened species like jaguars and mountain lions, citing specific ecological studies to argue that the 'may affect' standard is met for Section 7 consultation and that the Roadless Rule should not be rescinded.

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
    • “roadless areas are crucial in maintaining habitat quality and connectivity”
    • “critical for the population viability of large predators like mountain lions”
    • “occupancy of rarer species like mountain lions increased farther from roads”
    • “necessary to allow individuals to move freely throughout their home ranges”
  • Environmental Protection Biodiversity
    • “best interest of America's biodiversity and natural heritage”
    • “57% of vulnerable U.S. wildlife species have suitable habitat in roadless areas”
    • “preserving undegraded habitat and maintaining connectivity”
    • “sustain genetically diverse populations”
  • Scientific Research Evidence
    • “empirical research conducted throughout wild areas in the U.S.”
    • “Baker and Leberg, 2018”
    • “Trombulak & Frissell, 2000”
    • “Decades of ecological research throughout North America confirm the value”

What it names

Works cited
10.1016/j.gecco.2021.e0194310.1046/j.1523-1739.2000.99084.x10.1046/j.1523-1739.2001.99577.x10.1371/journal.pone.015422310.1371/journal.pone.0195436

The comment

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

Dear Chief Tom Schultz, I am commenting to oppose the rescission of the Roadless Rule as a graduate student studying wildlife ecology; empirical research conducted throughout wild areas in the U.S. has shown that roadless areas are crucial in maintaining habitat quality and connectivity. Living and working in the Chiricahuas and other Sky Island mountains in Arizona is why I fell in love with the landscapes and wildlife of the American Southwest, and has played a key role in shaping who I am as a scientist and conservationist. Working at the Southwestern Research Station was my first taste of the Southwest, and made me decide to study ecology in Southwest desert and mountain ecosystems. While hiking near Silver Peak in a Roadless Area, I observed my first mountain lion in the wild. I am a graduate student focused on predator ecology and conservation, and I know that wilderness areas unfragmented by roads like those found in the Chiricahuas are critical for the population viability of large predators like mountain lions as well as endangered species like jaguar and Mexican gray wolves. These apex predators require occupy massive territories and require unbroken connected habitat to move. Roadless areas provide key habitat for countless animals, but are particularly crucial for threatened and endangered species. A study of carnivores in several Arizona protected areas, including the Chiricahuas, found that occupancy of common species like bobcat and coyote were less likely to decrease near roads, while the occupancy of rarer species like mountain lions increased farther from roads — Baker and Leberg, 2018 (https://doi.org/10.1371/journal.pone.0195436). Jaguars and Mexican gray wolves are even more sensitive to human disturbance and dependent on intact wild habitat. Individual jaguars and Mexican gray wolves rely on montane habitat in multiple "Sky Island" ranges, separated by lowland desert. Roadless areas that encompass elevational gradients connecting these montane habitat resources are necessary to allow individuals to move freely throughout their home ranges, and consequently, secure the health of populations across Southern Arizona, New Mexico and into Mexico. The "may affect" standard does not require proof of population-level impact or demonstrated mortality. A reasonable possibility that road building, timber harvest, or increased access in the Chiricahua IRA disturbs, displaces, or degrades habitat for Jaguar (Panthera onca, E) is sufficient to trigger the Section 7 formal consultation obligation. The below studies further detail the importance of roadless protected areas for habitat conectivity of wide-ranging threatened species: “Klamath-Siskiyou case study mapped ~500 roadless areas and found roadless tracts bolster habitat representation and landscape connectivity, including smaller roadless patches. — Strittholt & DellaSala, 2001 (https://doi.org/10.1046/j.1523-1739.2001.99577.x)” “Species-level modeling shows 57% of vulnerable U.S. wildlife species have suitable habitat in roadless areas. Adding unprotected roadless areas to protected areas markedly reduces poorly-represented species of conservation concern. — Dietz et al., 2021 (https://doi.org/10.1016/j.gecco.2021.e01943)” “A foundational, frequently-cited review documenting seven categories of negative road effects: mortality from construction, vehicle collisions, modified animal behavior, alteration of physical and chemical environments, spread of exotic species, and increased human use. Establishes the scientific rationale for keeping roadless areas roadless and is cited extensively across the roadless-rule literature. — Trombulak & Frissell, 2000 (https://doi.org/10.1046/j.1523-1739.2000.99084.x)” “Identifies the most "natural" (least human-modified) corridors between large protected areas in the U.S. Many of the highest-priority corridors fall within or overlap inventoried roadless areas, providing direct evidence that maintaining roadless protections is critical to climate-adaptation connectivity strategies for wide-ranging species. — Belote et al., 2016 (https://doi.org/10.1371/journal.pone.0154223)” Decades of ecological research throughout North America confirm the value of roadless areas in preserving undegraded habitat and maintaining connectivity that is necessary for apex predators and other threatened species to sustain genetically diverse populations. Please act responsibly and in the best interest of America's biodiversity and natural heritage, and do not allow the Roadless Rule to be rescinded. With appreciation, Isabel DeVito MSc student studying predator community ecology Bachelor's in Organismal Biology and Ecology, Colorado College CommentID: RLC-20261007-ESFWD9

Keep learning. Keep speaking up.The Roadless Rule depends on public engagement. Share what you've learned.

© 2026 roadless.org - Defending America's Last Wild Forests

Privacy Policy|Questions or concerns? noroads@roadless.org|Follow us: @defendroadless