Comment Analysis · Docket FS-2025-0001

FS-2025-0001-552354

Opposes rescissionA1 strongSubstance 20/24Owed an answerPosted October 4, 2026 On Regulations.gov

In short: The comment establishes that the Draft EIS's carbon accounting in Volume I, page 74 contains a mathematical error by omitting the Eastern Region's 11.5 MMT from the net uptake calculation, resulting in a discrepancy between the reported total (43.5 MMT) and the sum of its components (32.0 MMT), which contradicts the agency's own cited source, Domke et al. 2023, Table 3.

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

Climate Carbon Storage
- “Roadless areas store carbon, buffer temperature extremes”
- “DEIS Regional Carbon Accounting Omits a Forest Service Region”
- “net carbon loss (31.5 MMT CO2) while the remaining regions had a net carbon increase”
- “an agency may not rest an environmental analysis on a characterization that the record it chose to rely on contradicts”
Environmental Protection Biodiversity
- “Timber harvest, associated road construction, and vegetation removal directly alter roadless character and degrade habitat quality”
- “provide intact refugia where species can shift in response to a warming climate”
- “Protect these lands, the diversity they hold”
- “Mineral extraction, oil and gas development, and associated infrastructure permanently industrialize otherwise undeveloped landscapes”
Recreation Tourism Public Use
- “destroying these lands for development and logging would be detrimental to tourism”
- “I am an archaeologist who loves to hike in nature and protect lands”
- “I wish to take my kids there for their first hikes”
- “revenue lost for those years will only grow if land is taken”
Legal Regulatory Framework
- “Both are factual corrections within the meaning of 7 CFR 1b.7(f)(2)(v)”
- “The issue is substantive under 7 CFR 1b.11(a)(53)”
- “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)”

What it names

Roadless areas: Rocky Mountain
Law cited: 463 U.S. 29 7 CFR 1b 7 CFR 1b.11(a)(53)
Works cited: Domke et al. 2023

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEvidenceRequestLegal

I spent college up in the western NC mountains and their beauty match no other, destroying these lands for development and logging would be detrimental to tourism and the environment. I am an archaeologist who loves to hike in nature and protect lands. Land is already being destroyed and developed on in many other places in the state, including where I live now. To see my refuge be affected by greedy corporations who want land and money hurts my heart greatly. Protect these lands, the diversity they hold and the emotional significance to millions of people. I recently went hiking in the Linville Gorge and visited the falls, it was amazingly beautiful and refreshing. After many trails were affected by Hurricane Helene and have only recently been reopened the revenue lost for those years will only grow if land is taken. I first hiked in the Appalachian mountains and I wish to take my kids there for their first hikes. I need them to experience the beauty of one of the oldest mountain ranges in the world in its natural state not in capitalistic infrastructure the exudes greed. Timber harvest, associated road construction, and vegetation removal directly alter roadless character and degrade habitat quality. Mineral extraction, oil and gas development, and associated infrastructure permanently industrialize otherwise undeveloped landscapes. Roadless areas store carbon, buffer temperature extremes, and provide intact refugia where species can shift in response to a warming climate. DEIS Regional Carbon Accounting Omits a Forest Service Region and Drops the Source's Own Attribution of the National Forest System Sink The Draft EIS's National Forest System carbon baseline misstates the source it cites, in two respects that appear within a single sentence and that the source itself resolves. At Volume I, page 74 (Alternative 3 – Modified Roadless Rule/IRA Boundaries, Potentially Affected Environment, Forest Vegetation), the Draft EIS states: "In 2021, forested lands within the national forest system sequestered 43.5 million metric tons (MMT) CO2, which follows national trends of increasing forest biomass in recent decades, however forests in the drier and more fire prone Intermountain, Rocky Mountain, Northern, and Southwestern Forest Service regions had net carbon loss (31.5 MMT CO2) while the remaining regions had a net carbon increase, sequestering 63.5 MMT CO2 (Domke et al. 2023)." First, the sentence's components do not produce its own total. A net loss of 31.5 MMT set against a net gain of 63.5 MMT yields a net sink of 32.0 MMT, not the 43.5 MMT the same sentence reports. The source shows where the discrepancy comes from. Domke et al. 2023, table 3 ("Carbon stock changes (net flux) from forest land remaining forest land within the National Forest System (NFS) by NFS region and year (MMT CO2 Eq.)"), gives 2021 net flux for all nine National Forest System regions. The four regions the Draft EIS names as net-loss regions are the four with positive values — Intermountain 11.5, Rocky Mountain 12.2, Southwestern 6.9, and Northern 0.9 — which sum to 31.5, the figure the Draft EIS reports correctly. The remaining five regions are Alaska (4.0), Eastern (11.5), Pacific Northwest (28.3), Pacific Southwest (5.7), and Southern (25.5), which sum to 75.0 MMT of net uptake, not 63.5. The Draft EIS's 63.5 is 75.0 less the Eastern Region's 11.5: the Eastern Region has been dropped from the uptake side while the total continues to include it. Restoring it reconciles the sentence, because 75.0 less 31.5 is 43.5, which is table 3's own net line for 2021. Both are factual corrections within the meaning of 7 CFR 1b.7(f)(2)(v), and under 7 CFR 1b.7(f)(3) the agency should cite where in the Final EIS each correction is accounted for. The issue is substantive under 7 CFR 1b.11(a)(53) because it bears on compliance with applicable laws: an agency may not rest an environmental analysis on a characterization that the record it chose to rely on contradicts. 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). Domke et al. 2023 is a Forest Service publication cited in the Draft EIS's own literature cited section, so these corrections require nothing of the agency beyond agreement with its own source.