Comment Analysis · Docket FS-2025-0001

FS-2025-0001-418096

Opposes rescissionA1 strongSubstance 18/24Owed an answerPosted September 16, 2026 On Regulations.gov

In short: The comment establishes that the Draft EIS contains an unreconcilable species count that fails to cross-reference the Biological Assessment and ignores the Dietz et al. (2021) finding on vulnerable species habitat, constituting a failure to consider an important aspect of the problem under 5 U.S.C. § 706(2)(A).

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, Evidence, 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

Wildlife Habitat
- “immense amount of species diversity”
- “rely on protections such as the Roadless act to remain intact”
- “rescission lifts road and timber-cutting prohibitions”
- “degrades species representation in the protected-area system”
Environmental Protection Biodiversity
- “fragmentation reduces biodiversity 13–75%”
- “suitable habitat in roadless areas”
- “vulnerable terrestrial vertebrate species”
- “Keep roadless areas roadless”
Legal Regulatory Framework
- “Under 7 CFR 1b.7(f)(2)(v), the Final EIS should state the exact species count”
- “7 CFR 1b.7(f)(2)(iii), the Final EIS should state the rescission’s effect”
- “5 U.S.C. § 706(2)(A)”
- “affect the Section 7 consultation record”
Recreation Tourism Public Use
- “dispersed camping with no sound but trickling creeks”
- “hikes spent IDing bird species”
- “trout lazily swimming near the edges of glacial lakes”
- “moments rely on these mountains remaining wild and protected”

What it names

Roadless areas: Pioneer Mountains
Law cited: 7 CFR 1b 7 CFR 1b.11(a)(53)
Works cited: Haddad et al. 2015

The comment

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

Dear Tom Schultz, I have traveled to Idaho to explore and appreciate the Smoky and Pioneer mountains every summer. I honestly don't know if I've encountered another high desert mountain terrain with as much beauty as these regions. The immense amount of species diversity and varying ecological landscapes are astounding and stunning and rely on protections such as the Roadless act to remain intact. Multiple nights spent dispersed camping with no sound but trickling creeks or rustling leaves, hikes spent IDing bird species I've not once encountered anywhere close to a road or civilization, hillsides full of high elevation blooms just thriving and making the air honey-scented. Stunning trout lazily swimming near the edges of glacial lakes that looked like jewels. All of these moments rely on these mountains remaining wild and protected. The Draft EIS's treatment of roadless-area wildlife habitat has real consequences for places like these “Species Count Not Reconciled to the Biological Assessment; Record Study on Species Representation Not Engaged The Draft EIS states (pp. 141, 168) that inventoried roadless areas provide habitat for "more than 300" threatened, endangered, and proposed species, per the "most recent USFWS and NMFS data." It gives no exact count, date, or cross-reference. The Draft Biological Assessment discloses its method — IRA shapefiles run through IPaC for the FWS list, NMFS species compiled from consultation records, both lists vetted by Forest Service staff and sent to the Services in September–October 2025, occurrence data from GBIF and NRM (BA p. 25) — but reports counts only by taxonomic group (e.g., 30 candidate bird species, 4 removed, 26 remaining, BA p. 161) and states no total. The BA also warns its databases do not differentiate between DPSs, "causing potential inflation" (p. 25). The "more than 300" figure cannot be traced to this method, and it is unclear whether it double-counts distinct population segments. Request 1: Under 7 CFR 1b.7(f)(2)(v), the Final EIS should state the exact species count, the date it reflects, whether DPSs are counted separately, and cross-reference the BA's Species Lists section wherever the figure appears — citing the correction per 7 CFR 1b.7(f)(3). Second, the figure does no analytical work. It appears only as background and is never tied to an effects conclusion — even though the same page states fragmentation reduces biodiversity 13–75% (Haddad et al. 2015), with effects "greatest in the smallest and most isolated fragments." The record already supplies the missing link: Dietz et al., "The Importance of US National Forest Roadless Areas for Vulnerable Wildlife Species" (2021), is in the Draft EIS's own reference list, cited in Vol. III (p. 37 n.201), and discussed at length in both the eight-state AG letter (Vol. III pp. 38–39) and the joint Tribal letter (Vol. III p. 498). Its finding: of 537 vulnerable terrestrial vertebrate species, 308 (57%) have suitable habitat in roadless areas — despite roadless areas covering only 2% of the contiguous U.S. — every roadless area holds habitat for at least two such species, and 81% of roadless acreage is suitable for at least five. Because this study is already in the agency's record, 7 CFR 1b.7(f)(2)(iv)'s bar on literature "not previously considered" doesn't apply — the agency need only analyze science it has already adopted. The chain is undisputed: rescission lifts road and timber-cutting prohibitions across the roadless network; the Draft EIS's own fragmentation finding predicts biodiversity loss, worst in small, isolated fragments; and Dietz et al. show this network is the disproportionate habitat base for the nation's vulnerable vertebrates — so shrinking it degrades species representation in the protected-area system. Request 2: Under 7 CFR 1b.7(f)(2)(iii), the Final EIS should state the rescission's effect on representation of species of conservation concern, using the corrected figure and engaging the Dietz finding — or explain in the response to comments why record science on this point doesn't apply. Both requests are substantive under 7 CFR 1b.11(a)(53): an unreconcilable affected-environment figure and an effects analysis that ignores a record finding are a failure to consider an important aspect of the problem, 5 U.S.C. § 706(2)(A). Both also affect the Section 7 consultation record, which rests on the same unstated baseline (BA p. 25).” Keep roadless areas roadless. Respectfully, CommentID: RLC-20260916-BIKIKN