Comment Analysis · Docket FS-2025-0001

FS-2025-0001-553602

Opposes rescissionA1 strongSubstance 15/24Owed an answerPosted October 5, 2026 On Regulations.gov

In short: The comment establishes that the Draft EIS fails to source the 36.7-million-acre wilderness figure and 44.7-million-acre roadless figure used in its effects analysis, and requests a factual correction in the Final EIS to identify the sources and effective dates of these figures in compliance with 7 CFR 1b.7(f)(2)(v) and 42 U.S.C. § 4332(2)(C).

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

Wildlife Habitat
- “preserve the environment for migratory birds”
- “Protect the migratory bird corridors”
- “reduce numbers of birds across America”
- “enjoy their work in pollination and insect control”
Legal Regulatory Framework
- “request a factual correction under 7 CFR 1b.7(f)(2)(v)”
- “compliance with applicable law within the meaning of 7 CFR 1b.11(a)(53)”
- “disclosure at issue is required by 42 U.S.C. § 4332(2)(C)”
- “Motor Vehicle Mfrs. Ass'n v. State Farm Mutual Automobile Ins. Co.”
Recreation Tourism Public Use
- “enjoyed the beauty and calm of the lands”
- “enjoyed birding for decades”
- “preserve what remains for our children”

What it names

Law cited: 463 U.S. 29 7 CFR 1b 7 CFR 1b.11(a)(53)

The comment

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

My family has long enjoyed the beauty and calm of the lands that will be harmed by creating more roads into our public lands. Please preserve what remains for our children. I have enjoyed birding for decades and want to preserve the environment for migratory birds. Protect the migratory bird corridors so we can enjoy their work in pollination and insect control. This change will reduce numbers of birds across America. The National Forest System subtotal is the one that carries weight here. The Draft EIS reports that the 2001 Roadless Rule applies to approximately 44.7 million acres of National Forest System lands (pp. 9, 11, 21). The 36.7-million-acre figure is the only quantity in this document that lets a reader set the designated wilderness estate on National Forest System lands against that roadless estate — and this section invites exactly that comparison when it states that inventoried roadless areas "provide popular, appropriate alternatives to wilderness areas because, although they contain many attributes similar to wilderness, a wider range of recreation opportunities with fewer restrictions is available." A comparison offered to the public in the effects chapter cannot rest on a denominator the document declines to source. I request a factual correction under 7 CFR 1b.7(f)(2)(v): that the Final EIS identify the source and effective date of both figures, and conform them to a current, identified national wilderness inventory as of the date of the Final EIS, giving the current figures wherever they differ from 111.9 million and 36.7 million acres. Under 7 CFR 1b.7(f)(3), the Final EIS should cite where that correction is accounted for. I raise this as a discrete correction and join no other request to it. If the agency's position is that no source can be identified for either figure, it should say so expressly and state the basis on which the figures were derived, so that the record shows what the Final EIS's description of the wilderness estate rests on. The accuracy and provenance of a baseline quantity presented in the effects chapter is information that meaningfully informs the consideration of reasonably foreseeable impacts and compliance with applicable law within the meaning of 7 CFR 1b.11(a)(53), and the disclosure at issue is required by 42 U.S.C. § 4332(2)(C). An agency may not present as established fact a figure its own record does not support. 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).