Comment Analysis · Docket FS-2025-0001

FS-2025-0001-346011

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

In short: The comment documents that the DEIS fails to project sediment delivery to over 7,000 municipal intakes, does not identify enforceable forest plan provisions equivalent to 36 CFR 294.12 and 294.13 for 24 million people's drinking water, and does not apply its cited 13-75% biodiversity fragmentation finding to the 40.1 million affected acres.

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

Water Quality Quantity
- “Road sediment is quantified and then set aside”
- “Twenty-four million people's drinking water is asserted away”
- “clean gravel and clear current are what make them fishable”
- “quantify projected sediment delivery to the more than 7,000 municipal intakes”
Environmental Protection Biodiversity
- “Fragmentation is quantified and not applied”
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
- “road it fragments habitat, brings weeds, causes roadkill”
- “This planet is as much theirs as ours”
Recreation Tourism Public Use
- “Fishing on national forests has been the highlight of many trips”
- “Trails in roadless areas have saved my life”
- “access to a peaceful float is paramount for every desert lovers sanity”
- “I feel so lucky to have seen so many critters that live here”
Resource Development Extraction
- “Having a road present with mining trucks and logging trucks would ruin this wholly”
- “This is purely a cash grab for extractive nature rape”
- “Look at mine waste piles and the liquid that comes out of them”
- “Just logged out mined out hell whole for your pockets to get bigger”

What it names

National Forests: Coronado National Forest Tonto National Forest
Law cited: 36 CFR 294.12

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Fishing on national forests has been the highlight of many trips getting to catch a fish on a friends birthday or show youngsters a real animal up close. Trails in roadless areas have saved my life. Multiple times I have felt the urge to kill myself. When I get down like this I take myself into nature and sure enough start to see the redeeming gleem of the world shine again. We need these places to feel whole to bring us back to what made us. Having a road present with mining trucks and logging trucks would ruin this wholly. Arizona is a dry hot state, access to a peaceful float is paramount for every desert lovers sanity. Please protect our public lands from private interests. I feel so lucky to have seen so many critters that live here. This planet is as much theirs as ours and its down right deplorable how we treat our neighbors. From the tapeworm point of view, god created man to feed the appetite of the tapeworm. If you have ever gotten the opportunity to move on this intimate way with nature. Did it not bring you a smile, a thrill, a sense of joy. Please protect public lands. Look up some of Ansel Adams work. If you see no redeemable worth in protecting these places for future generations. God help you. I have worked for the federal land management agencies. That money has so many better places to go support the public. This is purely a cash grab for extractive nature rape. Never have I as a land manager recommend a road it fragments habitat, brings weeds, causes roadkill, and makes more unsactioned roads. This shit is a plague on public land. Look at mine waste piles and the liquid that comes out of them. Do you want that in your wayer. I feel tremendously lucky to get to grow up with good public land to explore and grow in. I fear my kids wont have that at all. Just logged out mined out hell whole for your pockets to get bigger. I love the Tonto, I love the Coronado, i love the coccinicno, the kibaba and so on please protect our public lands. I beg of you The country I am writing about includes the Tonto National Forest and the Coronado National Forest. I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule. I raise the following issues for the record and ask that the agency respond to each of them: Issue 1: Road sediment is quantified and then set aside I fish these waters, and clean gravel and clear current are what make them fishable. What roads send downstream lands on the fish first, and on me right after. The DEIS: skid roads, trails, log landings and similar disturbances within timber sale areas are the main cause of soil erosion and "can contribute up to 90 percent of the sediment generated by timber sale activity." The number appears in the document; no projection of sediment delivery follows it. I ask that the agency quantify projected sediment delivery to the more than 7,000 municipal intakes downstream of these areas. Issue 2: Twenty-four million people's drinking water is asserted away As an angler I am on this water regularly, and the water I fish is the same water communities drink. What happens in the headwaters reaches all of us downstream. Approximately 24 million people use water originating within the potentially affected roadless areas, through more than 7,000 municipal intakes, and less than 12 percent of these watersheds are currently impaired. The DEIS says forest plans address sources of public drinking water without identifying one enforceable provision. I ask that the agency identify, forest by forest, which plan provisions are equivalent to 36 CFR 294.12 and 294.13 for municipal watersheds. Issue 3: Fragmentation is quantified and not applied Good fishing depends on intact, connected watersheds, not fragments. I fish, and I raise this because the agency quantified fragmentation and then never applied it. The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. The number appears; no projection across the 40.1 million affected acres follows. I ask that the agency apply the cited fragmentation range to the 40.1 million acres of potentially affected environment. I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule's protections. Where this proposal rests on factual conclusions that differ from the agency's own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record. Sincerely, Jacob Brown Chandler, Arizona