Comment Analysis · Docket FS-2025-0001

FS-2025-0001-583666

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

In short: The comment establishes that the Draft EIS fails to quantify the magnitude of stored-carbon loss under Alternative 2 by providing a denominator (0.9B Mg C) without estimating the numerator, and requests the agency supplement the analysis with bounded estimates using existing data from Table 16 and page 74.

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
- “Unquantified Magnitude Finding on Stored-Carbon Loss Under Alternative 2”
- “loss of stored carbon”
- “foregone sequestration under each alternative”
- “quantified or bounded estimate of stored-carbon loss”
Environmental Protection Biodiversity
- “Populations of frogs and salamanders have greatly decreased”
- “safe from human pollution and chemicals”
- “preserve our natural areas now”
- “keep our nation's land healthy”
Legal Regulatory Framework
- “An agency may not rest a finding of no material effect on a magnitude comparison whose terms it declines to supply”
- “Motor Vehicle Mfrs. Ass'n v. State Farm Mutual Automobile Ins. Co.”
- “5 U.S.C. 706(2)(A)”
- “supplement the forest vegetation and carbon analysis”

What it names

Law cited: 463 U.S. 29 5 U.S.C. 706

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeEA analysisAnalytical gapEvidenceRequestAlternative

Let's not give away the future “health” of our natural lands by rescinding the Roadless Rule. Large areas need to remain safe from human pollution and chemicals (logging and mining). The environment of western Washington has already been greatly affected by human beings. There's now a strange absence of mosquitoes at popular campgrounds. Populations of frogs and salamanders have greatly decreased. These are signals we can't ignore. We need to keep Alternative 1, the Roadless Rule. Alternative 2 has many flaws. For one thing, there is an Unquantified Magnitude Finding on Stored-Carbon Loss Under Alternative 2. The Draft EIS quantifies the carbon stock at issue and then declines to quantify the effect of the action on it, resting its finding on a comparison it never performs. At p. 74 the Draft EIS states: "Birdsey et al. (2025) estimate the IRAs contain about 5 percent of the stored forest carbon in the coterminous United States (0.9B Mg C)." At p. 87, under "Implications for Forest Vegetation, Health, and Carbon," the Draft EIS concedes the mechanism: "Under alternative 2, where future road construction, timber harvest, or non-commercial forest management remove vegetation, there would be a loss of stored carbon. Areas affected by permanent tree removal activities, such as permanent road construction, would lose capacity for carbon sequestration." It then disposes of the magnitude in a single sentence: "Given forest management objectives, these areas would be small compared to the overall carbon within the forested landscape within roadless areas." That is a quantitative comparison with only one term supplied. The Draft EIS gives the denominator - 0.9 billion Mg C - and never estimates the numerator. It does not state how many acres of the 44.7-million-acre potentially affected environment are expected to be roaded, harvested, or otherwise entered under alternative 2, what carbon density those acres carry, or over what period the loss and any recovery would occur. The finding that the loss would be "small" therefore rests on no disclosed quantity at any scale, and a reader cannot tell whether the agency is describing a fraction of a percent or a tenth of the stock it has just quantified. The Draft EIS's own source also undercuts the recovery assumption offered in mitigation. I request that the Forest Service supplement the forest vegetation and carbon analysis to disclose a quantified or bounded estimate of stored-carbon loss and foregone sequestration under each alternative, using the acreage and operability data already in Table 16 and the stock estimate already at p. 74; and, if the agency retains the finding that affected areas would be "small compared to the overall carbon within the forested landscape within roadless areas," that it disclose the quantities that comparison rests on. If no such estimate can be produced, the Draft EIS should state on the record why data the agency itself compiled will not support one. An agency may not rest a finding of no material effect on a magnitude comparison whose terms it declines to supply when it holds the data to supply them. 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). We need to keep Alternative 1 and make it permanent. It's vital to preserve our natural areas now. The Roadless Rule is the major baseline to keep our nation's land healthy.