Comment Analysis · Docket FS-2025-0001

FS-2025-0001-248177

Opposes rescissionA3 weakSubstance 11/24Owed an answerPosted August 22, 2026 On Regulations.gov

In short: The comment places on the record quantified data regarding ecological health trends in the Greater Yellowstone Ecosystem and cites EIS page 157 to argue that Alternative 1 (no action) is the only option that minimizes biodiversity loss and habitat fragmentation for listed species.

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

Wildlife Habitat
- “Wildlife species that depend upon retaining the inventoried roadless lands include grizzly bear, wolverine, wolf, elk, mule deer, pronghorn antelope, and moose”
- “habitat for such species”
- “maintain Inventoried Roadless Areas in their current protected status”
Environmental Protection Biodiversity
- “most vital signs of ecological health are stable or improving on national park, designated wilderness, wilderness study area, and inventoried roadless area lands”
- “long-term adverse effects on biodiversity by increasing habitat fragmentation, loss of connectivity, negative edge effects, and human disturbance”
- “area of wildlands and natural habitat is shrinking rapidly”
Governance Policy Process
- “I strongly urge that Alternative 1 (no action) of the 2001 Roadless Area Conservation Rule Rescission Draft Environmental Impact Statement be selected”
- “The EIS acknowledges that Alternatives 2 and 3 would degrade habitat”

What it names

Roadless areas: Wilderness Study Area

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Evidence

I strongly urge that Alternative 1 (no action) of the 2001 Roadless Area Conservation Rule Rescission Draft Environmental Impact Statement be selected. I have quantified changes in ecological health across the Greater Yellowstone Ecosystem during the past 30 years. The results show that most vital signs of ecological health are stable or improving on national park, designated wilderness, wilderness study area, and inventoried roadless area lands but most vital signs are deteriorating on general forest service or private lands. This is because habitats have been destroyed and fragmented due to population growth, home construction, roadbuilding, and increased motorized and nonmotorized recreation on the nonwilderness lands. Wildlife species that depend upon retaining the inventoried roadless lands include grizzly bear, wolverine, wolf, elk, mule deer, pronghorn antelope, and moose. The EIS acknowledges that Alternatives 2 and 3 would degrade habitat for such species. “Under alternatives 1, 2, and 3 any road construction, road reconstruction, and timber harvest could potentially have long-term adverse effects on biodiversity by increasing habitat fragmentation, loss of connectivity, negative edge effects, and human disturbance. These impacts would likely be more frequent and broader in scale under alternative 2. Impacts under alternative 3 would likely have a lesser effect on biodiversity than alternative 2, because the prohibitions on these activities would continue in some areas. Impacts to biodiversity would likely be the least under alternative 1, because current prohibitions allow limited exceptions for these activities” (EIS pg 157). In an America where the area of wildlands and natural habitat is shrinking rapidly, it is critical to maintain Inventoried Roadless Areas in their current protected status.