Comment Analysis · Docket FS-2025-0001

FS-2025-0001-613705

Opposes rescissionA2 moderateSubstance 10/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents that the DEIS fails to apply cited habitat fragmentation and carbon storage data to the 40.1 million acres of affected roadless areas, and requests that the agency quantify these impacts and reconcile the proposal with its own wildfire ignition data in Table 21.

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
- “watching the many birds that stop through roadless areas on their spring and fall migration”
- “bird richness declines with road presence in forested habitat”
- “road-noise experiments in a roadless area cut bird abundance by over a quarter”
Water Quality Quantity
- “roadless areas are vital to protecting our drinking water”
- “about 24 million Americans drink water that starts in these areas”
- “roads and their facilities can produce up to 90 percent of the sediment from a timber sale”
Climate Carbon Storage
- “inventoried roadless areas contain about 5 percent of the stored forest carbon”
- “no analysis of what harvest and roading would actually change”
- “quantify the change in carbon storage and sequestration under each alternative”
Recreation Tourism Public Use
- “quiet in a way that is genuinely rare”
- “see the stars without light pollution”
- “peace and wonder of the natural world”

What it names

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 gapEvidenceRequest

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The roadless areas I value are quiet in a way that is genuinely rare. I go there to see the stars without light pollution and to hike away from the pervasive hum of electricity. What draws me out is the peace and wonder of the natural world we are so blessed to have, and part of that is watching the many birds that stop through roadless areas on their spring and fall migration. That is what this rescission puts at risk, and I oppose it. The agency's own record documents what roads do to birds. The DEIS cites the findings 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. (source: DEIS; Kroeger et al. 2022; McClure et al. 2013; Ware et al.) The agency then cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent, but applies that range to none of the 40.1 million acres of potentially affected environment. That is not analysis; it is a number inserted and abandoned. I ask that the agency apply the cited fragmentation range to the 40.1 million acres before moving any further with this proposal. The fire rationale given for the rescission does not hold up against the agency's own data. The DEIS states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." This has impacted my family numerous times as human-sparked wildfires have threated their homes on multiple occasions. The agency must explain, in its own record, why the rescission departs from those findings and how it reconciles the proposal with the ignition data in DEIS Table 21, which the agency itself placed in the document. On water: roadless areas are vital to protecting our drinking water. The agency's own data show that about 24 million Americans drink water that starts in these areas. That water is also what the wildlife I go looking for depends on. Impaired streams are more prone to contamination, with ripple effects down to human communities, and the agency's own analysis acknowledges that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Opening these watersheds to roading and harvest is not a neutral decision, and the agency owes a clear accounting of what it expects to happen to stream quality in the affected watersheds. The carbon accounting in the DEIS has the same problem as the fragmentation analysis. The agency states: "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." Having stated that number, the document concludes that these lands will continue to sequester and store carbon, with no analysis of what harvest and roading would actually change. I ask that the agency quantify the change in carbon storage and sequestration under each alternative it is considering. Finally, I am sick and tired of my tax dollars going to the pockets of multimillionaire business owners instead of maintaining existing infrastructure that supports small business owners and keeps us all safe. The agency is already billions of dollars behind on maintaining the roads it has. Building new roads into country that has none, at public expense, to benefit timber interests, while that maintenance backlog grows, is not a responsible use of public funds. Fix the roads that already exist. The agency has not shown that this rescission serves anyone other than the narrow commercial interests that would benefit from access to these lands, and it should say plainly who it believes benefits and who bears the cost. Sincerely, Susan Massey Phoenix, AZ and Spokane, WA