Comment Analysis · Docket FS-2025-0001

FS-2025-0001-535283

Opposes rescissionA1 strongSubstance 15/24Owed an answerPosted October 4, 2026 On Regulations.gov

In short: The comment establishes that the Draft EIS and Economic Analysis rely on an uncited FY2024 recreation visitation figure and an unlisted citation (USDA Forest Service 2026a) for the National Visitor Use Monitoring program, creating a record deficiency that prevents the agency from articulating a rational connection between facts and the rule under 5 U.S.C. 706(2)(A) and State Farm.

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

Recreation Tourism Public Use
- “I hike in the thousands of acres in northern Wisconsin”
- “I spend money in these towns and if these wild areas were degraded, I would not spend tourism dollars there”
- “Recreation Opportunities and Setting - Effects of Alternative 3”
- “quantitative foundation of the recreation-economics discussion”
Legal Regulatory Framework
- “Unsourced FY2024 Recreation Visitation Figure and Unresolved NVUM Citation”
- “under 5 U.S.C. 706(2)(A) and Motor Vehicle Manufacturers Association v. State Farm”
- “substantive under 7 CFR 1b.11(a)(53)”
- “I request two factual corrections under 7 CFR 1b.7(f)(2)(v)”
Public Health Wellbeing
- “My mental and physical health would be degraded”
- “important for the overall well-being of our communities”
- “spoiled by roads, and or other developments”
Environmental Protection Biodiversity
- “I support keeping our forests and wildlife areas roadless”
- “Do not recind protections that are in place currently”
- “Please leave our wild places wild and roadless”

What it names

Law cited: 463 U.S. 29 5 U.S.C. 706 7 CFR 1b 7 CFR 1b.11(a)(53)
Works cited: U 2024U 2025aWhite et al. 2016

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequestLegal

I support keeping our forests and wildlife areas roadless. Do not recind protections that are in place currently. I hike in the thousands of acres in northern Wisconsin. My mental and physical health would be degraded if these places were spoiled by roads, and or other developments. These protected places are important for the overall well-being of our communities. I travel to the forest communities from 300 miles away. I spend money in these towns and if these wild areas were degraded, I would not spend tourism dollars there. Their livelihoods would suffer. Please leave our wild places wild and roadless Unsourced FY2024 Recreation Visitation Figure and Unresolved NVUM Citation at Draft EIS p. 220 At page 220 of the Draft EIS, under "Recreation Opportunities and Setting - Effects of Alternative 3 - Modified Rule - Economic Activity from Recreation in Roadless Areas," the Draft EIS states: "The 193 million acres administered by the Forest Service received approximately 164 million recreation visits in FY2024." That sentence carries no citation, and no citation anywhere in the paragraph supplies one. The paragraph's citations are attached to other propositions. White et al. 2016 is attached to the sentence immediately preceding the figure - "Some communities located around Federal recreation lands have a high dependence on economic inputs from recreation visitor spending and may experience negative economic conditions if visitation declines or visitor spending patterns change (White et al. 2016)" - which is a statement about community dependence, not about visitation counts. USDA Forest Service 2025a (National Forest and Grassland Economic Contributions, Forest Service Publication FS-1251) is attached two sentences after the figure, to "Visitor spending in FY2023 contributed approximately $16.2 billion to U.S. GDP and supported about 167,000 jobs, both full-time and part-time." Every other statistic in that paragraph is FY2023 and is drawn from that FY2023 source. The FY2024 visitation count is the only FY2024 datum in the paragraph, and a source cited for FY2023 spending and GDP cannot supply an FY2024 visit count. The same sentence appears at page 16 of the Economic Analysis, where the sentence order is different - the figure appears first and the White et al. 2016 citation two sentences after it - which confirms that no source is attached to the figure in either document. The Draft EIS also cites the National Visitor Use Monitoring program at page 220 as "(USDA Forest Service 2026a)." The string "Forest Service 2026" appears exactly once in Volume I, at that in-text citation. The References Cited section at pages 249-285 contains no entry for USDA Forest Service 2026a; its only National Visitor Use Monitoring entry reads "U.S. Department of Agriculture, Forest Service. 2024. Forest Service National Visitor Use Monitoring Data Dashboards." The Draft EIS therefore relies on an unidentified source for the one program capable of producing a national visitation figure, and the public cannot review the data the agency used. These are not questions of citation form. The FY2024 visitation figure is the quantitative foundation of the recreation-economics discussion at pages 220-222, which the Draft EIS uses to characterize the visitor spending and employment potentially affected by the rescission. A quantity asserted with no source in the record is not a fact found, and under 5 U.S.C. 706(2)(A) and Motor Vehicle Manufacturers Association v. State Farm Mutual Automobile Insurance Co., 463 U.S. 29, 43 (1983), the agency must articulate a rational connection between the facts found and the choice made. It cannot do so on a figure the record does not support. Because this concerns compliance with applicable law, the information is substantive under 7 CFR 1b.11(a)(53) and the issue cannot be certified as comparatively not of a substantive nature under 7 CFR 1b.7(j). I request two factual corrections under 7 CFR 1b.7(f)(2)(v), each of which the agency should account for by citation under 7 CFR 1b.7(f)(3): 1. Supply the source and data year for the FY2024 visitation estimate at Draft EIS page 220 and Economic Analysis page 16, or remove the figure from both documents. If the source is the National Visitor Use Monitoring program, identify the specific NVUM release and its publication date. 2. Add a complete References Cited entry for "USDA Forest Service 2026a," or correct the in-text citation at page 220 to the source actually relied upon. Because the same unsupported figure carries the recreation baseline in the Economic Analysis that supports the proposed rule, these corrections are owed both in the Final EIS and in the final rule's explanation of the economic effects on which it relies.