Comment Analysis · Docket FS-2025-0001

FS-2025-0001-322765

Opposes rescissionA1 strongSubstance 11/24Owed an answerPosted September 7, 2026 On Regulations.gov

In short: The comment establishes that the Draft EIS fails to provide a quantified nationwide cumulative impact analysis and relies on an uncited, non-reproducible timber harvest baseline, violating NEPA's requirement for a detailed statement of environmental effects and the hard-look standard.

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, 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.
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.
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.
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.

Topics

Recreation Tourism Public Use
- “specific quality of roadless country — its acoustic character, the absence of mechanical intrusion”
- “Finding a place without road noise or the sound of engines is increasingly difficult”
- “I journey into the wilderness and roadless areas specifically for the difficulty and sense of adventure”
- “enjoy the unique inheritance of America's national lands free from the impacts of noise and air pollution”
Legal Regulatory Framework
- “Uncited Methodology for Historical Timber Harvest Baseline in IRAs”
- “unsupported general statements do not satisfy the hard-look standard”
- “NEPA requires 'a detailed statement… on… reasonably foreseeable environmental effects'”
- “Absence of Quantified Nationwide Cumulative Timber Harvest, Road Construction, Sedimentation, and Fragmentation Analysis”
Water Quality Quantity
- “Rescission would diminish the few vibrant watersheds we have remaining”
- “support fishing, hunting, and drinking water”
- “Sedimentation”
Environmental Protection Biodiversity
- “High overlap exists between landslide susceptibility and areas of endemism for mammals, birds, and amphibians”
- “forests protecting both biodiversity and landslide risks to human society are important conservation targets”
- “fragmentation”

What it names

National Forests: Tongass National Forest
Roadless areas: Comanche Peak Adjacent Area
Law cited: 284 F.3d 1062 605 U.S. ___
Works cited: 10.1073/pnas.2113416118

The comment

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

Dear Chief Schultz: For an outdoor enthusiast, the specific quality of roadless country — its acoustic character, the absence of mechanical intrusion, the compounding effect of distance from a trailhead — is precisely what the 2001 Rule was designed to preserve, and what rescission would place in permanent jeopardy. The unique character of roadless areas makes them a invaluable birthright for us and future generations of Americans. Finding a place without road noise or the sound of engines is increasingly difficult and we must protect the few that remain. I journey into the wilderness and roadless areas specifically for the difficulty and sense of adventure they offer, far from the sanitized viewing points and car-dependent activities. Rescission would steal the opportunity from me and others to enjoy the unique inheritance of America's national lands free from the impacts of noise and air pollution. Rescission would diminish the few vibrant watersheds we have remaining which support fishing, hunting, and drinking water Regarding the Comanche Peak Adjacent Area in the Arapaho & Roosevelt NFs, Colorado: “The expansion of road networks degrades the slope stability and further increases the susceptibility to landslides. Deforestation, infrastructure construction, and mining triggered about 16% of fatal landslides from 2004 to 2016. High overlap exists between landslide susceptibility and areas of endemism for mammals, birds, and amphibians, which means that forests protecting both biodiversity and landslide risks to human society are important conservation targets. — Proceedings of the National Academy of Sciences, 2022 (https://doi.org/10.1073/pnas.2113416118)” Uncited Methodology for Historical Timber Harvest Baseline in IRAs The Draft EIS's timber harvest baseline for inventoried roadless areas rests on an uncited data pull. The document states that "the best available information on activities that have been implemented within IRAs over the last decade comes from the Forest Service Activity Tracking System" and reports "an average of 500 acres per year of timber harvest and a total of 1.8 million acres of hazardous fuels reduction," but nowhere identifies the specific FACTS query, parameters, or extraction date used to generate these numbers. The phrase "best available information" itself concedes limitations without disclosing their scope, and a single ten-year average obscures whether harvest activity is increasing, decreasing, or concentrated in particular years or forests — information directly relevant to evaluating the current Rule's effect on management flexibility. Under Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002), and APA 5 U.S.C. § 706(2)(A), unsupported general statements do not satisfy the hard-look standard. I request the agency cite the specific FACTS query and extraction date and disaggregate the average by year. Absence of Quantified Nationwide Cumulative Timber Harvest, Road Construction, Sedimentation, and Fragmentation Analysis The Draft EIS justifies rescinding roadless protections across up to 58 million acres nationwide based on generalized narrative about "changing and localized conditions, such as increasing wildfire risk, the spread of insect and disease infestations, and the need for community protection in the wildland-urban interface," and elsewhere asserts that the 2001 Roadless Rule "has contributed to the lack of active management of the national forests." Nowhere does the DEIS convert this narrative into a quantified nationwide or regionally stratified projection of harvest volume, road-mile construction, sedimentation, or fragmentation, even though it performs comparable granular quantitative analysis for the Tongass National Forest alone. NEPA requires "a detailed statement… on… reasonably foreseeable environmental effects of the proposed agency action," 42 U.S.C. § 4332(2)(C), and while Seven County Infrastructure Coalition v. Eagle County, No. 23-975, 605 U.S. ___ (2025), narrows review of effects outside agency authority, it does not excuse omitting cumulative effects of actions the agency itself controls. Tiering under 42 U.S.C. § 4336e(11) requires specific commitments, not open-ended deferral. I request a quantified nationwide analysis or an explicit, enforceable tiered commitment to project-level review. Twenty-five years of it working ought to count for something. Do not move forward with rescission. Respectfully submitted, CommentID: RLC-20260906-3PPQS4