Comment Analysis · Docket FS-2025-0001

FS-2025-0001-604276

Opposes rescissionA3 weakSubstance 13/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment establishes that the Draft EIS record is not reviewable due to specific citation deficiencies and inaccessible sources, and requests the agency to cure these gaps, extend the comment period, and disclose AI tools used in comment processing.

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

A3 weak: Substantive, but easier to set aside.

Owed an answer on Analytical gap.

Standard dismissals it defeats

Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
Outside the scope The agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.

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.
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.
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

Governance Policy Process
- “The record is not reviewable as published”
- “164 carry no citation”
- “extend or reopen the comment period”
- “disclose every software and AI tool used to sort, classify, summarize, or respond to the comments”
Environmental Protection Biodiversity
- “harm the rescission would do to habitat connectivity”
- “migratory birds”
- “roadless areas on the ground”
Water Quality Quantity
- “water quality”
- “harm the rescission would do to... water quality”
Cultural Heritage Indigenous
- “cultural resources”
- “Tribal consultation summary”

What it names

Roadless areas: Middle Prong Addition

Attachments

2 files. Counts as 338 — Counted from the files: The enclosed submissions were counted from the files themselves.

Enclosed submissions
Own letter

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapRequestAlternative

Docket No. FS-2025-0001 Document: FS-2025-0001-223869 Proposed Rescission of the 2001 Roadless Area Conservation Rule Comment of Nicholas E. Holshouser, nicholas@wanderingnature.com (roadless.org; Wandering Nature, LLC) I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and ask the agency to select the No Action alternative. This submission has two attachments. Attachment 1 is my Statement of Record Deficiencies. Attachment 2 is my full comment. This text is the cover; the attachments are the comment. Who I am. I developed roadless.org to support opposition to the rescission. I have advocated for the Pisgah and Nantahala National Forests for more than twenty years, and I know their roadless areas on the ground, the Middle Prong Addition above all. Part One of Attachment 2 states my interest and the harm the rescission would do to habitat connectivity, migratory birds, cultural resources, recreation and local economies, and water quality, with references. The record is not reviewable as published (Attachment 1). The Draft EIS record cannot be fully checked by the public asked to comment on it: of 224 factual claims examined, 164 carry no citation; of 398 entries in the DEIS bibliography, 105 cannot be obtained; 49 entries are never cited; 14 claims cite sources silent on the figure attributed to them; 12 rest on internal agency sources; seven sources the footnotes rely on are absent from the References section; and the government-letters volume is misfiled in the record index. Across the five record documents, 927 of 1,461 cited sources checked remain paywalled, print-only, or dead-linked after a renewed effort to obtain them; Appendix B of Attachment 2 lists them. On September 10, 2026, I filed FOIA Request No. 2026-FS-WO-07195-F for the agency's copies. I request that the agency produce or link those sources in the docket, cure the citation gaps, and extend or reopen the comment period so that the public may review a checkable record. I reserve the right to supplement this comment upon production. What the comment contains (Attachment 2). 267 numbered items, each a self-contained concern on a specific passage of the Draft EIS, its Cost Benefit Analysis, the two draft Biological Assessments, the Tribal consultation summary, or Volume III, with a pinpoint citation and a specific request. The items are organized under the Draft EIS's own subjects, Parts Two through Eighteen, and consolidated into eight requests in Part Nineteen. Appendix A indexes every item. I request that the agency respond to each item individually in the Final EIS and cite where each action taken is accounted for. AI and software in comment processing. Item 267 asks the agency to disclose every software and AI tool used to sort, classify, summarize, or respond to the comments on this rule, to validate those tools, and to place the complete record of their use in the administrative record. Attachments: (1) Holshouser_Deficiency_Statement_FS-2025-0001.pdf, 5 pages; (2) Holshouser_Comment_FS-2025-0001.pdf, 654 pages, a single file containing Parts One through Nineteen and Appendices A and B.