Comment Analysis · Docket FS-2025-0001

FS-2025-0001-600603

Opposes rescissionA1 strongSubstance 14/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment establishes that the Draft EIS presents specific wilderness acreage figures (111.9 million and 36.7 million acres) on page 195 without citations or dates, rendering them unverifiable and failing to meet the NEPA requirement for a detailed statement, and requests that the Final EIS either source 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, 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

Environmental Protection Biodiversity
- “protect them in every way”
- “untouched wild spaces and vistas”
- “complete destruction of our natural environs and wild spaces”
- “lose a birthright”
Legal Regulatory Framework
- “NEPA requires a "detailed statement"”
- “7 CFR 1b.11(a)(53)”
- “7 CFR 1b.7(f)(2)(v)”
- “identify the source of both the 111.9-million-acre... total”
Recreation Tourism Public Use
- “spend as much time as possible in all of these places”
- “life-affirming to see untouched wild spaces”
- “Recreation Opportunities and Setting”

What it names

Law cited: 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 knowledgeAnalytical gapRequestLegal

I am a 57 year old Oregonian and CTO of a clearing broker-dealer. Like many of us, I care deeply about the public lands that comprise the American wilderness. I moved here from Texas over 15 years ago in large part due to the natural beauty and the wild outdoors, which are a direct result of our historic conservation and preservation of these spaces. National parks, national forests, state parks and forest, bureau of land management -- I spend as much time as possible in all of these places. They are the very heart and soul of America, and of The West, and we must protect them in every way. I just drove from Portland, OR to Eureka, CA down 101 with a brief stop in the wilderness along the Rogue River halfway between Powers and Agness on Forest Road 33. It is rough and slow going, as challenging and inconvenient as it is inspirational, breathtaking, life-affirming to see untouched wild spaces and vistas as stunning as crossing the Rogue River. Open any of this to development -- topple the first domino -- and complete destruction of our natural environs and wild spaces will proceed in what seems like a blink of an eye. Do this now, my yet-unborn grandchildren -- my kids are 21 -- will lose a birthright that has until now conveyed to all Americans, one of the most valuable and precious things we have. Please do not rescind the roadless rule. P.S. AI didn't write this, and I didn't ask for or receive any help from people or machines. Straight from my head and heart, filled with love and hope, with equal parts concern and conviction. 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.