Comment Analysis · Docket FS-2025-0001

FS-2025-0001-571511

Opposes rescissionA1 strongSubstance 15/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment establishes that the DEIS fails to meet NEPA requirements by analyzing only boundary-focused alternatives rather than varying prohibitions and exceptions based on resource criteria, while documenting the commenter's professional and recreational standing in affected areas and the specific risk of karst aquifer degradation from roadless area development.

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, Alternative, 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

Water Quality Quantity
- “concerned about sedimentation caused by building roads & logging”
- “degrade drinking-water supplies on the surface”
- “destroy underground conduits of water such as those found in karst landscapes”
- “Nearly 40% of the drinkable groundwater in the U.S. comes from karst aquifers”
Environmental Protection Biodiversity
- “habitats change dramatically when the continuous forest is interrupted by open space”
- “most fragile ecosystems on the planet can be hiding in plain sight”
- “remote & unbroken environment”
- “jeopardized habitats that are reliant on the underground water supply”
Legal Regulatory Framework
- “deeply troubled by the gaps in supporting evidence as well as failures of adequate planning”
- “The DEIS does not analyze a reasonable range of alternatives”
- “NEPA requires 'a reasonable range of alternatives to the proposed agency action'”
- “No alternative analyzed in detail varies the prohibitions & exceptions themselves”

What it names

National Forests: Bridger-Teton National Forest Chattahoochee National Forest Daniel Boone National Forest Monongahela National Forest Shasta-Trinity National Forest Tonto National Forest
Law cited: 42 U.S.C. Sec. 4332

Attachments

1 file. Counts as 1 — Counts as one: The attachments enclose no one else's submissions; the comment counts as one.

Own letter

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Local knowledgeEA analysisAnalytical gapEvidence

Hello. I am an engineer for the energy industry who (in addition to my engineering degree) also holds a degree in Wildlife Biology from a top agriculture University. In addition to my professional credentials, I have also contributed thousands of volunteer hours to the exploration & mapping of caves across the U.S., including those in the Grand Canyon NP, Mammoth Cave NP, Tonto National Forest, & Fern Cave Federal Wildlife Refuge. I have also volunteered as a citizen scientist assisting the collection of microbes caves. Those microbes are studied at top universities by labs focused on novel drug discovery, material science, & carbon sequestration. My recreational interests are extensive -- I cave, rock climb, backpack, day hike, overland/off-road, etc. throughout the United States. In the last 10 years, I have travelled to several dozen National Forests for these activities including the Chattahoochee NF, Bridger-Teton NF, Daniel Boone NF, Monongahela NF, Petrified Forest NF, & Shasta-Trinity NF. While doing so, I strive to shop locally, dine locally, & support the small rural towns. For me, the biggest draw to areas such as this is the remote & unbroken environment. As any wildlife biologist can attest, habitats change dramatically when the continuous forest is interrupted by open space such as those created by roads. Additionally, as any caver can attest, some of the most fragile ecosystems on the planet can be hiding in plain sight (often just under our feet). I am especially concerned about sedimentation caused by building roads & logging in areas that would have otherwise been roadless. Not only can such activities degrade drinking-water supplies on the surface, but it can also destroy underground conduits of water such as those found in karst landscapes. This impact wields a double-edged sword: both the humans & the habitats that are reliant on the underground water supply are jeopardized. This impact isn't limited to a few rural towns or scattered populations, either. Nearly 40% of the drinkable groundwater in the U.S. comes from karst aquifers! Professionally, I am no strange to Federal documentation. I frequently write supporting documents for nuclear power plants that are reviewed by the U.S. Nuclear Regulatory Commission. I draw upon this experience when I review the documentation "supporting" the proposal to rescind the Roadless Rule & I am deeply troubled by the gaps in supporting evidence as well as failures of adequate planning. Below is an example of such: The DEIS does not analyze a reasonable range of alternatives. The USFS states this itself: "The alternatives evaluated in detail in this DEIS focus on the geographic locations (boundaries) in roadless rulemaking" (DEIS p. 34). Alt. 1 retains the 2001 Rule's prohibitions; Alt. 2 removes them nationwide; Alt. 3 "would continue the existing Rule's exceptions and provides for locally led boundary modifications" (DEIS p. 35). No alternative analyzed in detail varies the prohibitions & exceptions themselves according to stated resource criteria. NEPA requires "a reasonable range of alternatives to the proposed agency action... that are technically and economically feasible, and meet the purpose and need of the proposal," 42 U.S.C. Sec. 4332(2)(C)(iii), & the DEIS cites the parallel requirement at 7CFR1b.7(h) on the same page where it describes its own range as boundary-focused. The rest of this comment is attached as a file because the online portal's character limit is preventing the discussion of the matter in full.