Comment Analysis · Docket FS-2025-0001

FS-2025-0001-609703

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

In short: The comment documents that the Butterfly Roadless Area in the Coronado National Forest requires species-specific formal consultation for the Loach Minnow, which cannot be satisfied by generic programmatic findings, and details how road construction would disrupt hydrology, facilitate invasive species establishment, and degrade habitat for federally endangered species.

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

Environmental Protection Biodiversity
- “uplifts other species and wildlife”
- “fragment habitat corridors”
- “protects forests and undisturbed soils”
- “degrade these ecosystem benefits”
Water Quality Quantity
- “Hydrological Disruption”
- “alter the natural flow of water”
- “disrupt the seepage and groundwater conditions”
- “alter hydrology”
Cultural Heritage Indigenous
- “sacred to our indigenous people”
- “sacred places to exist”
- “unique area on our sky island”
Climate Carbon Storage
- “vital carbon storage”
- “combating climate change”

What it names

National Forests: Coronado National Forest
Roadless areas: Butterfly Roadless Area

The comment

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

To the USDA Roadless Rule Rulemaking Team: As someone who spends time in the natural parts of this land, for both mental health, and science education for the high school students I work with and mentor- it is imperative that I talk to you about how our way of life, and the animals and land we protect would all be altered for ourselves and future generations. Short-sighted profit-seeking behavior, that which drives this proposed rescission of this rule, weighs very little against the real impacts on our world, and on life. This was the first place I went hiking when I came to Tucson, Arizona. I mentor students at a local high school, all whom love this area and know it to be a unique area on our sky island, a mountain long established as sacred to our indigenous people of this land. This trail has given me the gift of natural beauty, but most importantly, provided a home for many, and must be maintained. Being immersed in this land and part of this place brings us back to who we really are, and what we are meant to connect to. So many humans forget their place in this world, their connection to the earth. The roadless rule allows these sacred places to exist, allows us to remember ourselves. More importantly, it uplifts other species and wildlife, and protects forests and undisturbed soils that act as vital carbon storage, combating climate change. Roadless areas are key components of healthy, intact landscapes that drive outdoor recreation economies across the country. Developing and degrading these roadless lands with new roads and resource extraction will degrade these ecosystem benefits and cost the public dearly. Roadless areas are worth far more when left intact and undeveloped, and will cost the taxpayers so much. Beyond cost to our taxpayer dollars, there is an inevitable impact on humanity and wildlife ecosystems. I CHOOSE A NO ACTION ALTERNATIVE Regarding the Butterfly Roadless Area in the Coronado National Forest, Arizona: Hydrological Disruption and Invasive Species Establishment — Road construction requires fill material, culverts, and drainage modifications that alter the natural flow of water through the landscape. In the Butterfly Peak Research Natural Area and riparian zones, these changes disrupt the seepage and groundwater conditions that sustain federally endangered Arizona eryngo and Huachuca water-umbel. Simultaneously, the disturbed soil and compacted roadbed create ideal conditions for invasive grasses—buffelgrass, red brome, and Mediterranean grass—which are already documented as threats in the Coronado National Forest. These invasives establish along road corridors and alter fire regimes, increasing the risk of uncharacteristic wildfires that would destroy the mixed conifer and riparian forest habitat that supports both the spotted owl and the area's endemic plants. Without roadless protections, the Butterfly Roadless Area IRA becomes available for road building, timber sales, and motorized recreational access. These activities alter hydrology, fragment habitat corridors, introduce edge effects, and increase human disturbance — all of which may affect Loach Minnow (Tiaroga cobitis, E). The formal consultation obligation for Loach Minnow (Tiaroga cobitis, E) in the Butterfly Roadless Area IRA, Coronado National Forest, is species-specific. The agency cannot satisfy it through a generic programmatic consultation or a blanket finding covering all listed species across all roadless areas. Each species in each area requires its own consultation finding and its own determination of effect. "Construction of roads, utility corridors and other human infrastructure kills any sessile or slow-moving animal and all vegetation in the path of the feature. Roads and other linear infrastructure negatively impact wildlife through increased mortality, decreased habitat amount and quality, changing species movement patterns, and fragmentation of populations into smaller subpopulations, which are more vulnerable to local extinction." — Maine DEP NECEC Follow-up Joint NGO Comments (Appendix B), citing Trombulak and Frissell 2000, 2000 I urge the Secretary to decline this rescission and preserve the existing roadless area protections. With kind regards, Rachel Mueller CommentID: RLC-20261007-PR837Y