Comment Analysis · Docket FS-2025-0001

FS-2025-0001-555396

Opposes rescissionA1 strongSubstance 18/24Owed an answerPosted October 5, 2026 On Regulations.gov

In short: The comment establishes that the FEIS fails to perform a required balancing of competing values against its own conservation evidence, specifically citing Dietz et al. (2021) at Volume III page 39, and requests specific corrections to the analysis of changed conditions on pages 18-20 and disclosure of drinking-water watershed populations.

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
- “kayaking and exploring the outdoors”
- “opportunities for solitude, recreation, and connection to the natural world”
- “hike mountain trails, and seek out quiet backcountry spaces”
- “recreation economy they support”
Water Quality Quantity
- “essential for clean water”
- “damage the headwaters and streams”
- “drinking-water source watersheds”
- “increase erosion and sedimentation”
Wildlife Habitat
- “wildlife habitat”
- “fragment habitat”
- “ecological richness is extraordinary”
- “long-term forest resilience”
Legal Regulatory Framework
- “FEIS supplement the rationale”
- “7 CFR 1b.7(f)(2)(iii)”
- “correct the statement at page 20”
- “disclose the population served by drinking-water source watersheds”

What it names

Law cited: 7 CFR 1b

The comment

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

Dear Decision-Makers, I am writing to express my strong support for maintaining and protecting the Roadless Rule. As a professor at Furman University and someone who regularly spends time kayaking and exploring the outdoors of Upstate South Carolina and the mountains of North Carolina, I have seen firsthand how valuable intact, undeveloped public lands are to both people and ecosystems. Roadless areas provide some of the most important remaining opportunities for solitude, recreation, and connection to the natural world in our region. For those of us who paddle local waterways, hike mountain trails, and seek out quiet backcountry spaces, these lands are not abstract policy concerns — they are living landscapes that shape our quality of life and our sense of place. Protecting roadless areas is also essential for clean water, wildlife habitat, and long-term forest resilience. Roads and associated development can fragment habitat, increase erosion and sedimentation, and damage the headwaters and streams that support downstream communities, recreation, and biodiversity. In the southern Appalachians, where the ecological richness is extraordinary, these protections are especially important. The mountains of North Carolina and the broader Southern Appalachian region are treasured not only for their beauty, but for the environmental services they provide and the recreation economy they support. Keeping these areas roadless helps preserve the character of the landscape for future generations while reducing costly and unnecessary disturbance. I urge you to uphold the Roadless Rule and reject efforts to weaken protections for these public lands. Once roadless character is lost, it is exceedingly difficult — and often impossible — to restore. Please protect these forests, streams, and wild places for the benefit of current and future generations. Thank you for considering my comment. Sincerely, Brandon Inabinet Purpose and Need Asserts a Balancing of Competing Values Without Performing It Against the Record's Own Conservation Evidence I request three things. 1. That the FEIS supplement the rationale for the proposed rule to state the conservation values of inventoried roadless areas as the Department's own record documents them, including the Dietz et al. (2021) findings published at Volume III page 39, and to explain why the changed conditions recited at pages 18 through 20 outweigh them. 7 CFR 1b.7(f)(2)(iii). 2. That the FEIS correct the statement at page 20 that changed conditions "diminish the basis for a national prohibition," or supply the analysis that supports it. 7 CFR 1b.7(f)(2)(v). 3. That the FEIS disclose the population served by drinking-water source watersheds within the 44.7 million acres of inventoried roadless areas, or state on the record that the Department cannot determine it.