Comment Analysis · Docket FS-2025-0001

FS-2025-0001-357483

Opposes rescissionA2 moderateSubstance 14/24Owed an answerPosted September 12, 2026 On Regulations.gov

In short: The comment establishes that the agency's exclusion of a temporary-road alternative from detailed study is procedurally circular and that its reliance on land management plans is undermined by the admission that 45 plans were revised during a period of regulatory uncertainty, thereby documenting a specific deficiency in the EIS's analysis of alternatives and environmental safeguards.

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, Alternative.

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

Governance Policy Process
- “treatment of alternatives in this environmental review is the most serious procedural failure”
- “rationale is circular”
- “must add it to the range of alternatives analyzed in the final EIS”
- “binding schedule for completing them exists”
Wildlife Habitat
- “watching birds, looking for elk, deer, bears, and coyotes”
- “wildness that makes those forests worth hiking into”
- “destroying the landscape values”
- “birds and wildlife I watch in these forests”
Recreation Tourism Public Use
- “spend our time watching birds”
- “worth hiking into”
- “bring people like me to Cibola National Forest”
Water Quality Quantity
- “Clean water”
- “long-term integrity of national forest landscapes”

What it names

National Forests: Cibola National Forest

The comment

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

The trails through Cibola, Santa Fe, and Carson National Forests are where my partner, our friends, and I spend our time watching birds, looking for elk, deer, bears, and coyotes. The wildness that makes those forests worth hiking into depends directly on the roadless protections this proposal would eliminate, and I oppose rescission of the 2001 Roadless Area Conservation Rule. The agency's treatment of alternatives in this environmental review is the most serious procedural failure here. As stated in the Alternatives Considered but Eliminated from Detailed Study section, "An alternative that considered maintaining existing inventoried roadless area boundaries and prohibitions on permanent road construction while allowing temporary road construction and timber harvest was considered but eliminated from detailed study as not being responsive to the purpose and need." That rationale is circular. The purpose and need was written to require deregulation, so any alternative that preserves meaningful protection is defined out of contention before analysis begins. An alternative that allows temporary-road-based hazardous fuel treatment and selective harvest inside inventoried roadless areas, without authorizing permanent roads, could plausibly meet the agency's stated fire and forest-health objectives without destroying the landscape values that bring people like me to Cibola National Forest. The agency must explain, in non-circular terms, why such an alternative cannot meet those objectives, and must add it to the range of alternatives analyzed in the final EIS. The agency's reliance on land management plans as the primary safeguard under alternatives 2 and 3 is equally troubling. The Potentially Affected Environment section concedes that "45 of those were revised between 2001 to 2011 when the status of the Roadless Rule was uncertain due to litigation. Therefore, these plans are less likely to have incorporated IRAs into their management areas or provided specific direction for these areas." The agency cannot simultaneously claim that existing plans will protect inventoried roadless areas and acknowledge that most of those plans were developed without adequate roadless-specific direction. Before any rescission is finalized, the agency should identify in the final EIS which specific plan amendments or revisions would be required to provide equivalent protection for each affected forest, and should not move forward until those updates are completed or a binding schedule for completing them exists. The birds and wildlife I watch in these forests do not recognize the difference between a rescinded federal rule and a plan revision that has not yet happened. Clean water, responsible use of public funds, and the long-term integrity of national forest landscapes are all bound up in this decision. I ask that the agency treat each of these points as requiring a substantive response before it takes final action.