Comment Analysis · Docket FS-2025-0001

FS-2025-0001-606693

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

In short: The comment establishes that the Green Mountain National Forest's outdated documentation regarding unassessed roads and trails, combined with the commenter's status as a small business entity, demonstrates a specific deficiency in the agency's capacity to analyze the full scope of impacts from the proposed rule.

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 Evidence.

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

Economic Impact Fiscal
- “My business is a small entity and will be greatly impacted by this proposed rule”
- “further economic divides in this country”
- “exploitation without consequence by corporations and special interests”
- “bringing no benefit to the majority of Americans”
Governance Policy Process
- “agency's inability to see / comprehend the full scope of businesses impacted”
- “Many Forest Plans and their supporting documents are outdated, expired”
- “conflicts of interest as well as sheer ignorance of conditions on the land”
- “The Forest Service is not equipped with the funding or personnel to assess its current conditions”
Public Land Access Rights
- “provide opportunity for recreation to the elites while leaving most Americans excluded”
- “leaving most Americans excluded from the benefits of their national forests”
- “Public trust is at stake here”

What it names

Roadless areas: Green Mountain

The comment

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

My comments of 19 September 2025 still stand and continue to be largely ignored in these documents. My business is a small entity and will be greatly impacted by this proposed rule; the agency's inability to see / comprehend the full scope of businesses impacted by usage of federal lands is a limitation on the agency's ability to conduct analysis of impacts deriving from this action. Many Forest Plans and their supporting documents are outdated, expired, and originating from a previous century. They are so far beyond usefulness that much of the public no longer holds any faith or trust in the agency to do meaningful or scientifically valid work. Public trust is at stake here. With recent changes to the NEPA process and additional changes to forest monitoring protocols, agency staff have greater license to use their best judgment and the best available science in decision-making. This flawed approach opens doors to conflicts of interest as well as sheer ignorance of conditions on the land. Green Mountain National Forest documents on non-native invasive plants clearly stated almost 20 years ago that most roads and trails on the forest have NOT been assessed or inventoried. That situation has only gotten worse with staff reductions and budget cuts, yet the agency somehow thinks blind judgment calls are a good idea? Partners could theoretically help rectify this dire scenario, but some of those such as Audubon and The Nature Conservancy, recreation interests, and game organizations have financial relationships with the agency that continue to bring potential for conflicts of interest. These special interests or Friends Groups cannot be the solution for an underfunded / under-resourced federal agency. This ill-conceived rescinding of the 2001 Roadless Conservation Rule will work in tandem with the proposed Travel Management Rule to further economic divides in this country. It will continue to provide opportunity for recreation to the elites while leaving most Americans excluded from the benefits of their national forests. It will also open the land to "exploitation without consequence" by corporations and special interests, while again bringing no benefit to the majority of Americans. Future generations will have fewer resources because of the greed exemplified by this rule. The Forest Service is not equipped with the funding or personnel to assess its current conditions or the impacts of its actions. Societies and the world at large have changed drastically while the agency has not; in fact, the Forest Service is so locked into its behaviors and internal culture that it cannot evolve. With such limitations, there are a handful of "goods" that the agency could perform, but poorly conceived, short-term actions like eliminating the Roadless Rule are not a "good." With adoption of this rule, the Forest Service will continue to fail the people it is charged to serve. Thank you for taking my comment.