Comment Analysis · Docket FS-2025-0001

FS-2025-0001-603250

Opposes rescissionA0 noneSubstance 7/24Posted October 7, 2026 On Regulations.gov

In short: The comment establishes the commenter's personal standing through direct residence, recreational use, and professional involvement in specific IRAs (Brush Mountain, Unita, Wasatch-Cache) and documents their legal expertise in NEPA, NFMA, and APA compliance regarding the roadless rule recission.

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

A0 none: Counted, not answered.

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.
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.
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.
Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
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.
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.

Topics

Legal Regulatory Framework
- “proposed recission of the roadless rule is illegal”
- “draft EIS is deficient in every way, arbitrary and capricious”
- “lacks any valid alternatives analysis”
- “furthest thing from well-done, comprehensive, or legally sound”
Recreation Tourism Public Use
- “hiking, camping, and stargazing at Brush Mountain IRA”
- “families bonded hiking to tree stands”
- “time I spent hiking in the IRA is by far the most memorable”
- “peace and tranquility they offer to everyone who visits”
Environmental Protection Biodiversity
- “value they provide to big and small game species”
- “intact wilderness, like IRAs, are better for the ecosystem”
- “more productive environmental services, like water filtration and carbon sequestration”
- “goes against all valid science to say that repealing the roadless rule will have any scientific, environmental, or ecological benefit”
Forest Management Wildfire
- “more resistant to fire when properly managed under the already existing rules”
- “Forest Service is already incapable of maintaining the roads that it has already built”
- “Opening up acreage to build more roads when the ones that exist are not well maintained is illogical”

What it names

National Forests: Jefferson National Forest White Mountain National Forest
Roadless areas: Brush MountainBrush Mountain EastWhite Mountain

The comment

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

I have had the privilege of living very near to several IRA's in the last 6 years. I fundamentally oppose the recission of the roadless rule, and I believe it is not based in logic, science, or the law. The roadless rule should not be repealed and should remain as it has been. I went to college in Southwest Virginia and spent as many weekends as I could hiking, camping, and stargazing at Brush Mountain IRA and Brush Mountain East IRA in the Jefferson National Forest. During deer hunting season I volunteered with the Virginia Department of Wildlife Resources to test deer harvested for chronic wasting disease. A few Saturdays during the season we tested deer from various parking lots throughout Montgomery county. Many of those hunters hunted in the National Forest, and many on Brush Mountain. Kids harvested their first does in this IRA and families bonded hiking to tree stands in the Forest they had been hunting for decades. Brush Mountain and Brush Mountain East is a sacred place to everyone who has spent any time in Craig, Roanoke, and Montgomery county. Whether just passing through on a hike, spending four years of weekends there while in college nearby, or living there for generations, the IRA designation of Brush Mountain protects it as a sacred place. In 2021 I had the opportunity to camp host at a camground at the base of Mount Timpanogos. Growing up in the dense green forests of Appalachia, the wide-open Utah landscape kept me in awe every day. I spent every spare moment exploring the area, spending extra time hiking in the Unita IRAs and Wasatch-Cache Utah IRA. I spent a lot of time off-roading in rock crawlers, hauling my camper around to dispersed camp sites, and mountain biking all over Utah, but the time I spent hiking in the IRA is by far the most memorable. The Forest Service is already incapable of maintaining the roads that it has already built. Opening up acreage to build more roads when the ones that exist are not well maintained is illogical. As a lover of motorized recreation, never once have I thought, I wish there were more roads in the national forest. As a hiker and lover of intact wilderness for their ecological and environmental benefits, I am grateful every day for IRAs and the value they provide to big and small game species, the ecosystem overall, and for the peace and tranquility they offer to everyone who visits. The science shows that intact wilderness, like IRAs, are better for the ecosystem, for more productive environmental services, like water filtration and carbon sequestration, and in more cases than not, more resistant to fire when properly managed under the already existing rules and regulations under the roadless rule. It goes against all valid science to say that repealing the roadless rule will have any scientific, environmental, or ecological benefit. Finally, but maybe most importantly, the proposed recission of the roadless rule is illegal. The draft EIS is deficient in every way, arbitrary and capricious, and lacks any valid alternatives analysis. I am finishing my final semester of law school and have spent the last two years reading nearly every past and present NEPA, NFMA, and APA case. I have been a part of a team that has filed two lawsuits to stop the USFS from continuing on with two logging projects in the White Mountain National Forest. In my time working on these suits I have read some well-done Environmental Assessments and Environmental Impact Statements. I know what a well-done, comprehensive, and legally sound NEPA process looks like, and this roadless rule recission process is the furthest thing from well-done, comprehensive, or legally sound.