Comment Analysis · Docket FS-2025-0001

FS-2025-0001-479700

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

In short: The comment establishes that the Draft EIS fails to disclose the vintage or reconciliation status of the 9.3-million-acre Tongass inventoried roadless area figure, rendering the baseline and alternative comparisons arithmetically unreliable given acknowledged technical corrections.

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

Legal Regulatory Framework
- “NEPA requires the environmental impact statement to describe the affected environment accurately”
- “7 CFR 1b.7(h)(3)(iv)”
- “technical corrections may be approved by the Chief”
- “factual corrections, 7 CFR 1b.7(f)(2)(v)”
Governance Policy Process
- “Draft EIS uses a 9.3-million-acre figure... without stating the vintage”
- “no stated reconciliation”
- “baseline against which every alternative's effects are measured”
- “supplementing, improving or modifying of analyses”

What it names

National Forests: Tongass National Forest
Law cited: 42 U.S.C. 4332 7 CFR 1b 7 CFR 1b.7(h)(3)(iv)

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeAnalytical gapEvidence

Tongass 9.3-Million-Acre IRA Figure Carries the Alternatives Arithmetic with No Disclosed Vintage or Reconciliation The Draft EIS uses a 9.3-million-acre figure for inventoried roadless area within the Tongass National Forest as a term in its baseline and in the acreage comparison among alternatives, but nowhere states the vintage of that figure or whether it has been reconciled against the technical corrections the Draft EIS itself says have already changed the roadless inventory. At page 11, under "Inventoried Roadless Areas," the Draft EIS states that "[t]he 2001 Roadless Rule applies to approximately 44.7 million acres of National Forest System lands, including about 9.3 million acres within the Tongass National Forest." Footnote 4 to that same passage states: "While the original rule listed 58.5 million acres, mapping modernization and technical corrections reduced that to 58.2 million acres." At page 21, the Draft EIS states that "[m]odification of IRA boundaries would require rulemaking, though technical corrections may be approved by the Chief." Those three passages, taken together, establish the defect. The agency states that inventoried roadless area boundaries are subject to technical correction approved administratively by the Chief, outside rulemaking. It discloses that mapping modernization and technical corrections have already moved the national roadless total by approximately 300,000 acres. It then carries the Tongass figure without stating when the Tongass inventory was last corrected, what any such correction changed, or the date as of which the "current national roadless area maps" it relies on at page 21 are current. Page 12 likewise states that "[c]urrent areas are reflected in national maps at the Forest Service Roadless Area website" without a date. No citation in the Draft EIS attaches to the 9.3-million-acre figure itself. A reader therefore cannot determine from the document whether the corrections that reduced 58.5 million acres to 58.2 million acres touched the Tongass inventory at all. This is not a request for background information, because the figure is load-bearing arithmetic in the comparison of alternatives. Alternative 1 "[a]pplies to inventoried roadless areas totaling 44.7 million acres; including 9.3 million acres of the Tongass National Forest" (p. 21), and the Draft EIS designates alternative 1 the no-action alternative under 7 CFR 1b.7(h)(3)(iv), stating that "[i]t establishes a benchmark, or environmental baseline, against which the effects of the other alternatives are compared" (p. 21). Under alternative 2, "the 9.3 million acres of inventoried roadless area within the Tongass National Forest would be included in the 44.7 million acres no longer managed according to the 2001 Roadless Rule" (p. 23). Under alternative 3, the same 9.3 million acres is one of three addends in the stated removal total: 4.5 million acres of non-National Forest System lands and congressionally designated areas, plus 17.9 million acres within a half mile of existing roads or within the wildland-urban interface outside the Tongass, plus 9.3 million acres of Tongass inventoried roadless area, together making the "31.7 million acres" the alternative removes and leaving the "13 million acres" it continues to manage under the 2001 Rule (pp. 23-24). The cause-and-effect relationship is therefore direct and arithmetic. If the Tongass figure has moved since the inventory from which it was taken — as the Draft EIS's own account of Chief-approved technical corrections indicates it may have — then the acreage the Draft EIS reports as removed from roadless protection under alternatives 2 and 3, the residual it reports as retained under alternative 3, and the baseline against which every alternative's effects are measured are each misstated by the same amount. The disclosed magnitude of the action, and so the disclosed magnitude of its effects on the Tongass National Forest, is no more accurate than the figure. NEPA requires the environmental impact statement to describe the affected environment accurately, 42 U.S.C. 4332(2)(C), and the Draft EIS itself invokes 7 CFR 1b.7(h)(3)(iv) to make alternative 1 the benchmark against which every other alternative is measured. A baseline whose principal Tongass acreage term carries no stated vintage and no stated reconciliation cannot perform that function. The Department's procedures identify the making of factual corrections, 7 CFR 1b.7(f)(2)(v), and the supplementing, improving or modifying of analyses, 7 CFR 1b.7(f)(2)(iii), as actions the agency takes in response to substantive comments.