Comment Analysis · Docket FS-2025-0001

FS-2025-0001-442093

Neutral / unclearA2 moderateSubstance 5/24Owed an answerPosted September 17, 2026 On Regulations.gov

In short: The comment establishes a request to adopt an 'open unless closed' presumption for over-snow vehicle use on National Forest System lands, arguing that existing access should be maintained unless specific documented needs for closure exist.

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 Alternative.

Standard dismissals it defeats

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.

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.
Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
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.
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.

Topics

Recreation Tourism Public Use
- “protect reasonable access to National Forest System lands”
- “open unless closed presumption for over-snow vehicle use”
- “existing snowmobile access should serve as the starting point”
- “responsible recreation and conservation can coexist”
Governance Policy Process
- “Require the Forest Service to consider new trails... during forest-level planning”
- “Encourage local Forest Service officials to work directly with organized snowmobile groups”
- “closures based on documented resource, safety, legal, or management needs”

The comment

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

As representatives of Michigan’s snowmobile community, we believe the Rule should recognize the unique nature of over-snow vehicle (OSV) recreation and protect reasonable access to National Forest System lands. We support establishing an “open unless closed” presumption for over-snow vehicle use. Existing roads, trails, and appropriate riding areas should remain available for snowmobile use unless a closure or restriction is required by law or supported by a documented resource, safety, or management need. For forests that do not already have winter travel plans, existing snowmobile access should serve as the starting point rather than requiring riders to continually justify long-established winter recreation. Our tracks melt with the snow. When adequate snow conditions exist and riders operate responsibly, snowmobiles can travel across the winter landscape without creating the permanent roadbed, rutting, or soil disturbance associated with ground-contact travel. For Michigan snowmobilers, a better policy would: Establish an “open unless closed” approach for appropriate OSV use, with closures based on documented resource, safety, legal, or management needs. Recognize the seasonal and temporary nature of snowmobile travel over adequate snow cover and frozen ground. Maintain existing snowmobile access unless there is a demonstrated reason to restrict it. Require the Forest Service to consider new trails, connectors, roads, and riding opportunities during forest-level planning. Encourage local Forest Service officials to work directly with organized snowmobile groups when developing winter travel plans. Protect natural resources while recognizing that responsible recreation and conservation can coexist.