Comment Analysis · Docket FS-2025-0001

FS-2025-0001-542932

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

In short: The comment establishes that the Draft EIS fails to cite the source or date for the 36.7-million-acre National Forest System wilderness figure used in the Alternative 3 effects analysis, rendering the basis for the recreation substitution finding untraceable and unsupported by the record.

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
- “open pristine lands to motorized vehicles”
- “beauty in our parks will be preserved”
- “non-motorized recreation opportunities”
- “recreation substitution finding”
Legal Regulatory Framework
- “7 CFR 1b.11(a)(23)”
- “7 CFR 1b.7(f)(2)(v)”
- “Draft EIS states”
- “rational connection between the facts found and the choice made”
Environmental Protection Biodiversity
- “create pollution”
- “pristine roadless places”
- “wilderness character”
- “National Wilderness Preservation System”

What it names

Law cited: 36 CFR 219.7(c)(2)463 U.S. 29 7 CFR 1b 7 CFR 1b.11(a)(23)7 CFR 1b.11(a)(53)
Works cited: Landres et al. 2015

The comment

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

I recently retired and plan to spend the next few years exploring our national parks. Rescinding the roadless rule will open pristine lands to motorized vehicles which will create pollution. Leave our pristine roadless places alone so the beauty in our parks will be preserved for my (and other’s) arrival!! Uncited National Forest System Wilderness Acreage Relied On for the Alternative 3 Recreation Substitution Finding The Draft EIS states, at page 195, under *Recreation Opportunities and Setting — Effects of Alternative 3 – Modified Rule — Wilderness*: "The National Wilderness Preservation System includes approximately 111.9 million acres; of these, approximately 36.7 million acres are on National Forest System lands." Neither figure carries a citation, and the National Forest System sub-total is the one this comment concerns. The only scientific citation anywhere in that paragraph is Landres et al. 2015, which appears three sentences later and is attached to a different proposition — the five qualities the Forest Service and other wilderness-administering agencies read into "wilderness character" under Section 2(a) of the Wilderness Act. It is not offered in support of either acreage. The next citation in the passage, 36 CFR 219.7(c)(2) at page 196, is attached to the plan-level identification of recommended wilderness. Between them the Draft EIS also states that National Forest System wilderness areas "receive about 13 million visits each year or 8 percent of the visits to all lands in national forests," and that figure is uncited as well. The Draft EIS does not identify the inventory the 36.7-million-acre figure was drawn from, or the date as of which it was current. I do not contend the figure is numerically wrong. I contend that a reader of this Draft EIS cannot determine what it rests on, and that this matters because the Draft EIS puts the figure to work in its effects analysis rather than offering it as background. The same paragraph reasons that "Congressionally designated wilderness within the National Forest System offers many similar recreation opportunities as roadless areas (except for motorized and mechanized trail activities)," and the analysis of Alternative 3 relies on that comparison to treat the non-motorized recreation opportunities now afforded by inventoried roadless areas as remaining available on other National Forest System lands after rescission. The 36.7-million-acre figure is the quantity that makes that substitution appear sufficient: it is the measure of how much comparable land the agency says remains. If the figure is drawn from an inventory that predates subsequent designations, boundary adjustments, or transfers, or if it counts acreage the agency does not in fact manage for the qualities it invokes, then the extent of substitute opportunity is overstated and the effect of rescission on non-motorized recreation in inventoried roadless areas is correspondingly understated. Neither the reader nor the decisionmaker can test that, because the source is not given. This states an issue within the meaning of 7 CFR 1b.11(a)(23): rescission of the 2001 Roadless Rule is the action, the availability of comparable non-motorized recreation opportunity on other National Forest System lands is the reasonably foreseeable effect, and the National Forest System wilderness acreage is the sole quantity the Draft EIS offers to measure that effect. An unsourced quantity cannot support the finding it is used to support. I request a factual correction under 7 CFR 1b.7(f)(2)(v): that the Final EIS name the source of the 36.7-million-acre National Forest System wilderness figure and the date as of which that source was current, and state, where the effects analysis relies on the figure, how it supports the finding that designated wilderness provides recreation opportunity comparable to inventoried roadless areas. I do not ask the agency to adopt any particular database; I ask that whatever source it used be identified, so that the figure is traceable. Under 7 CFR 1b.7(f)(3), the Final EIS should cite where that correction is accounted for. This is a single request and I join no other to it. If the agency's position is that no source can be identified, it should say so expressly and state the basis on which the figure was derived, so that the record shows what the Final EIS's account of the wilderness estate rests on. The provenance of a quantity the effects analysis relies upon is information that meaningfully informs the consideration of reasonably foreseeable impacts and compliance with applicable laws within the meaning of 7 CFR 1b.11(a)(53). An agency must articulate a satisfactory explanation for its action, including a rational connection between the facts found and the choice made, supported by evidence in the record. Motor Vehicle Mfrs. Ass'n v. State Farm Mutual Automobile Ins. Co., 463 U.S. 29, 43 (1983); 5 U.S.C. § 706(2)(A).