Comment Analysis · Docket FS-2025-0001

FS-2025-0001-582907

Opposes rescissionA1 strongSubstance 13/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment establishes that the Draft EIS fails to provide verifiable sources or dates for the specific wilderness acreage figures cited on page 195, violating NEPA's requirement for a detailed statement, and requests that the Final EIS either cite the sources and dates for these figures or correct them.

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, 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
- “Getting away from road noise is exactly what I go to public land for”
- “I lose the ability to find quiet spaces away from the city”
- “without hearing loud engines”
- “see and experience the undeveloped beauty of our country's incredible landscapes”
Environmental Protection Biodiversity
- “devastating impacts on the biodiversity of the region”
- “biodiversity loss”
- “destruction of the healthy ecosystems”
- “protect our roadless areas”
Climate Carbon Storage
- “greatly reduce the natural carbon sink that the forests provide”
- “immediate negative effect on climate warming”
- “impacts of climate warming in Asheville”
Legal Regulatory Framework
- “Neither figure carries a citation”
- “NEPA requires a 'detailed statement'”
- “The agency cannot answer this concern by citing the passage in which the figures appear”
- “I request that the Final EIS do one of two things”

What it names

Roadless areas: Craggy MountainSanta Rita
Law cited: 7 CFR 1b 7 CFR 1b.11(a)(53)

Attachments

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

Supporting material

The comment

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

Dear Secretary Rollins and Chief Schultz, Getting away from road noise is exactly what I go to public land for, and the 2001 Rule is a big part of why that's still possible in so many places. Spending time hiking Craggy Mountain is what made me fall in love with Asheville when I first moved here. Being able to quickly get away from the city, into the clean brisk air, seeing the beauty of the Blue Ridge mountains spread out across the skyline is truly an indescribable feeling. I remember sitting at the top of Craggy Gardens, a sea of clouds below us. It was so incredibly peaceful and serene. If the roadless rule is rescinded, I lose the ability to find quiet spaces away from the city. I lose my escape. I lose the ability to connect with nature, to have amazing once in a lifetime experiences with wildlife like this past weekend seeing elk up close in a pristine landscape. The reason I go on hikes is to get away from road noise. To see and experience the undeveloped beauty of our country's incredible landscapes. I should be able to go hiking in Craggy Gardens, camping in Yellowstone, or exploring the Santa Rita Mountains near my grandmother's home, without hearing loud engines, without seeing the desctruction of the healthy ecosystems that make our country America the Beautiful. Allowing clear-cutting of forests on publlc land will greatly reduce the natrual carbon sink that the forests provide. This will have an immediate negative effect on climate warming and biodiversity loss. We know too well the impacts of climate warming in Asheville, after suffering the devastation brought on by Hurricane Helene. The microrefugia have already suffered immense canopy loss due to the hurricane. Rescinding the roadless rule would have truly devastating impacts on the biodiversity of the region. Wilderness Acreage Figures at Page 195 Stated Without Any Citation The Draft Environmental Impact Statement states, at page 195 (Chapter 3, "Recreation Opportunities and Setting," Effects of Alternative 3 – Modified Rule, subsection "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. The sentence is unsourced on its face. The next citation in the subsection, Landres et al. (2015), is attached to a different proposition — the five qualities of wilderness character interpreted from Section 2(a) of the Wilderness Act — and supports nothing about acreage. Nothing in the surrounding text identifies where either number came from, and a reader cannot trace either figure from the text to any entry in the literature cited. These are the two figures by which the Draft EIS characterizes the resource whose treatment under this rulemaking it then analyzes, and they are stated as fact inside the effects analysis for the Modified Rule alternative rather than in an introductory or background passage. National Wilderness Preservation System acreage is not a fixed quantity; it changes with each congressional designation, so a figure stated without a source and without a date cannot be checked by anyone. NEPA requires a "detailed statement" under 42 U.S.C. § 4332(2)(C). The Department's own procedures define substantive information to include information that meaningfully informs "compliance with applicable laws, executive orders, and regulations" (7 CFR 1b.11(a)(53)), and provide for "[m]aking factual corrections" as a response to a substantive comment (7 CFR 1b.7(f)(2)(v)). A headline resource figure that the public cannot trace to any source is not a verifiable element of a detailed statement. The agency cannot answer this concern by citing the passage in which the figures appear, because that passage is the one lacking the source. I request that the Final EIS do one of two things: (1) identify the source of both the 111.9-million-acre National Wilderness Preservation System total and the 36.7-million-acre National Forest System subset, state the date to which each is current, and add that source to the literature cited; or (2) if no source supports the figures as stated, correct them. Under 7 CFR 1b.7(f)(3), the response should cite where in the Final EIS or the supporting proposal record the action taken is accounted for. Rescinding protections for roadless areas would be a step backward that I don't think the Department can justify — to the public, to the record, or to the forests themselves. I trust that you will act in the best interest of our forests, wildlife, and people like me, and protect our roadless areas. Thank you for keeping the roadless rule intact. With appreciation, CommentID: RLC-20261006-6GXJTA