Comment Analysis · Docket FS-2025-0001

FS-2025-0001-383181

Opposes rescissionA1 strongSubstance 15/24Owed an answerPosted September 14, 2026 On Regulations.gov

In short: The comment establishes that the DEIS fails to disclose the quantified invasive-species threat to 60% of listed plant taxa found in the Biological Assessment, relies on an unsupported assumption that action alternatives do not differ in operability, and fails to demonstrate compliance with Executive Order 13751 regarding invasive species management.

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

Environmental Protection Biodiversity
- “value the biodiversity that the Roadless Rule protects”
- “non-native invasive plant species”
- “threatened by invasive or non-native species”
- “rich landscape that only a roadless forest can offer”
Legal Regulatory Framework
- “Compliance with Executive Order 13751”
- “7 CFR 1b.11(a)(53)”
- “The FEIS should correct the disclosure”
- “The agency cannot demonstrate compliance with an executive order”
Scientific Research Evidence
- “Coffin et al. 2021 is a source the agency itself relies on”
- “The DEIS analyzes non-native invasive plant species at pp. 114-116”
- “The finding that the action alternatives do not meaningfully differ is unsupported”
- “quantifies the stake: Of the 134 plant taxa in this analysis 81 (60 percent)”

What it names

Roadless areas: Craggy Mountain
Law cited: 7 CFR 1b.11(a)(53)Executive Order 13751

Attachments

1 file. Counts as 1 — Counts as one: The attachments enclose no one else's submissions; the comment counts as one.

Own letter

The comment

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

Dear Forest Service Leadership: As a wildlife observer I recognize the 2001 Rule as the federal instrument most directly responsive to that fact; I write in opposition to the proposed rescission. Craggy Mountain is one of the first wild places I connected with in Western North Carolina. As a recent transplant from the west coast, I value the biodiversity that the Roadless Rule protects. From the northern red oak to the Dark-eyed Junco, the forest provides the wonders and rich landscape that only a roadless forest can offer. The DEIS analyzes non-native invasive plant species at pp. 114-116 and identifies roads as a vector at p. 150: "Road construction, routine roadside mowing, and the use of roads have been shown to facilitate the spread of non-native invasive plant species." This comment is directed at three specific defects inside that analysis. 1. The extent figure measures current infestation, not introduction risk in areas that are currently uninfested. The North Carolina Wildlife Resources Commission put the distinction to the agency directly: "IRAs often have less non-native invasive plants due to the lack of roads and other pathways generally associated with their spread and distribution" (DEIS Vol. III, p. 210). On that record the low current percentage identifies the resource at risk; it does not bound the effect. The FEIS should correct the disclosure to state what the figure measures, what it does not, and what the acknowledged mapping gap does to it. 2. The finding that the action alternatives do not meaningfully differ is unsupported and is contradicted by the section's own numbers. At p. 116 the DEIS concludes that "the alternatives are not expected to differ significantly in regard to their contributions to the introduction and spread of invasive species." The stated basis is that "The areas of likely operability for these activities are not expected to be significantly different under alternatives 2 and 3." No support is offered for that assumption. The same section states that "Alternative 3 has fewer acres in the potentially affected area than alternative 2" (p. 115) and reports different mapped acreages for the two - 309,000 against 270,787. A conclusion that the alternatives are indistinguishable for this resource, resting on an operability premise the analysis never demonstrates, removes invasive species from the comparison the environmental impact statement exists to make. The FEIS should either supply the operability comparison the assumption requires or withdraw the finding. 3. The listed-plant exposure the agency has already quantified appears nowhere in the DEIS. The Draft Biological Assessment for USFWS species states at p. 342: "Roads create favorable conditions for invasive plants by providing light gaps, dispersal corridors, and reduced competition. Vehicles and road maintenance equipment can spread invasive plant seeds, further contributing to their proliferation (Coffin et al. 2021)." At p. 344 it quantifies the stake: "Of the 134 plant taxa in this analysis 81 (60 percent) are threatened by invasive or non-native species." Neither that finding, nor the 60-percent figure, nor the 134-taxon denominator appears anywhere in the DEIS. The DEIS's invasive-plant section at pp. 114-116 does not mention listed species at all, and the DEIS's ESA discussion refers the reader away, stating that "the Biological Assessments contain the full evaluations for the ESA-listed species and designated critical habitat" (p. 169). The agency therefore holds, in one record, a quantified invasive-species threat to 60 percent of the listed plant taxa it analyzed and an invasive-species effects analysis for the action that permits the road construction - and connects them in neither document. Coffin et al. 2021 is a source the agency itself relies on. The FEIS should carry the Assessment's finding into the invasive-plant analysis and disclose the exposure of listed plant taxa by alternative. Compliance with Executive Order 13751. The DEIS opens this section by quoting the order, which "directs all Federal agencies to address invasive species concerns and refrain from actions likely to increase invasive species problems" (p. 114). It closes the same section by finding that alternatives 2 and 3 "could potentially increase the extent or the number of invasive plant species in the affected environment area" (p. 116). The agency cannot demonstrate compliance with an executive order it has itself invoked while the record's only quantified statement of invasive-species exposure for listed plants - 81 of 134 taxa, at Biological Assessment p. 344 - is absent from the analysis supporting the decision. This is a compliance concern within the meaning of 7 CFR 1b.11(a)(53), and it is owed a reasoned explanation in the final rule as well as a corrected analysis in the FEIS. The Roadless Rule belongs on the books. Hopefully,