Comment Analysis · Docket FS-2025-0001

FS-2025-0001-253017

Opposes rescissionA1 strongSubstance 12/24Owed an answerPosted August 22, 2026 On Regulations.gov

In short: The comment establishes that the DEIS fails to analyze the specific loss of dispersed shooting, hiking, and camping opportunities due to road construction and associated regulatory buffers, and documents that the wildfire rationale is unsupported by data on human-caused ignitions and maintenance backlogs.

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

A1 strong: Must be answered — it names the law.

Owed an answer on Analytical gap, Evidence, Legal.

Standard dismissals it defeats

  • 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.
  • 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.
  • 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.

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.
  • 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.
  • Outside the scope The agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.

Topics

  • Recreation Tourism Public Use
    • “I hike, camp, and shoot on National Forest System lands”
    • “removes far more shooting-capable ground than its physical footprint”
    • “degrades hiking, camping, and general living”
    • “recreational and natural value is partially derived from substantial natural darkness and quiet”
  • Wildlife Habitat
    • “new roads fragment habitat for bear, elk, and native trout”
    • “roughly 25% of federally listed animal species have habitat in roadless areas”
    • “area fragmentation degrades hiking, camping, and general living”
  • Water Quality Quantity
    • “Roads bring noise, dust, exhaust, and sediment into the air as well as headwaters”
    • “headwaters serving tens of millions of Americans”
  • Forest Management Wildfire
    • “the wildfire rationale is unsupported”
    • “human ignitions are roughly four times likelier near roads than in roadless country”
    • “Access is not a constraint; workforce capacity and a $6.9 billion road maintenance backlog are”

What it names

National Forests
Croatan National Forest
Law cited
36 CFR 261.10

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapEvidenceRequestLegal

I oppose full rescission. I hike, camp, and shoot on National Forest System lands, and the DEIS does not analyze how road construction forecloses those uses. Roads are not neutral. Each corridor redraws concentrations of vehicle traffic and dispersed camping, and under 36 CFR 261.10(d) and 261.58(m) every campsite, structure, and occupied area imposes a 150-yard no-discharge buffer, plus a prohibition on firing across or on a road. One spur, especially as it pertains to extraction industries, removes far more shooting-capable ground than its physical footprint and often severs long, unobstructed lanes with competent backstops that my, and many other Americans long range marksmanship and hunting hobbies, require (something a 25-100yd urban enclosed range cannot substitute). For example, the Croatan National Forest (just three hours away from me) banned target shooting after expanded road access, followed by commercial and private development, constricted shooting areas and interrupted countless potential safe shooting lanes, until eventually any terrain that could’ve been used as an assured backstop fell outside of areas where it was legal to shoot, with the final decision coming after a stray round managed to travel .8 miles through the forest itself and into a private residence. Rescission spreads that pattern across another 44.7 million acres. The DEIS reduces recreation harm to a single $6.1 million annual figure and never disaggregates dispersed shooting, despite the EXPLORE Act directive to identify target shooting opportunities. Please analyze acreage and terrain types remaining available for lawful dispersed shooting under each alternative. The same area fragmentation degrades hiking, camping, and general living. Roads bring noise, dust, exhaust, and sediment into the air as well as headwaters serving tens of millions of Americans. Additionally, headlights and operational lighting are brought that much deeper into places whose recreational and natural value is partially derived from substantial natural darkness and quiet. Aside from people, new roads fragment habitat for bear, elk, and native trout; roughly 25% of federally listed animal species have habitat in roadless areas. Lastly, the wildfire rationale is unsupported. About 90% of wildfires are human-caused, and human ignitions are roughly four times likelier near roads than in roadless country. USDA concedes 11.3 million roadless acres already sit near existing roads and remain untreated. Access is not a constraint; workforce capacity and a $6.9 billion road maintenance backlog are. I urge selection of the no-action alternative.

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