Comment Analysis · Docket FS-2025-0001

FS-2025-0001-265065

Opposes rescissionA1 strongSubstance 4/24Owed an answerPosted August 24, 2026 On Regulations.gov

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 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

  • Economic Impact Fiscal
    • “fails to fully account for the economic impacts”
    • “economic benefits associated with health wilderness and forest lands”
    • “economic cost to communities, states, and the nation would run in the billions of dollars”
  • Legal Regulatory Framework
    • “violation of the Administrative Procedures Act”
    • “arbitrary, capricious, an abuse of discretion”
    • “5 U.S.C. § 706(2)(A)”
  • Environmental Protection Biodiversity
    • “maintaining higher ecological integrity”
    • “purer watersheds”
    • “greater biodiversity than roaded or developed landscapes”

What it names

Law cited
EO 12866

The comment

This proposed rule fails to fully account for the economic impacts as required by EO 12866. This deficiency is material and the proposed rule should be abandoned as is. Any economic analysis must take into consideration the economic benefits associated with health wilderness and forest lands. Roadless wilderness scientifically proven to be healthier, maintaining higher ecological integrity, purer watersheds, and greater biodiversity than roaded or developed landscapes. These are massive economic benefits from the current status quo that are not accounted for in this proposed rule. If the proposed rule is enacted, the economic cost to communities, states, and the nation would run in the billions of dollars, while the new economic benefits would only be in the millions of dollars. This failure to consider the economic impacts also results in this proposed rule being in violation of the Administrative Procedures Act. Adopting the proposed rule as is would result in the rule being "arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law" under 5 U.S.C. § 706(2)(A) for its failure to properly address critical evidence presented in the record.

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