Comment Analysis · Docket FS-2025-0001

FS-2025-0001-270685

Opposes rescissionA2 moderateSubstance 14/24Owed an answerPosted August 26, 2026 On Regulations.gov

In short: The comment establishes that the agency's Draft Environmental Impact Statement (DEIS) and Cost Benefit Analysis fail to quantify the increased wildfire ignition risk from new road access, reconcile the lack of net economic benefit with the proposed road expansion, or properly assess the impact on small businesses and reliance interests in the Bridger-Teton National Forest.

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

A2 moderate: Hard to dismiss — it shows cause and effect.

Owed an answer on Analytical gap, 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.
  • 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.

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.
  • 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
    • “Bears, elk, moose, and many other species depend on that landscape staying whole”
    • “Losing the roadless character of the Bridger-Teton would fracture exactly the uninterrupted habitat these species require”
    • “elk avoid areas near roads and select habitat away from them”
    • “increased contact and conflict that come with open roads in grizzly habitat can ultimately end in grizzly mortality”
  • Recreation Tourism Public Use
    • “home to countless world-class trails, including the Continental Divide National Scenic Trail”
    • “recreation losses of at least $6.1 million a year”
    • “My use of the Continental Divide National Scenic Trail and the wildlife habitat it passes through has been shaped by the protections this rule provides”
    • “outfitters, guides and tour operators as affected”
  • Economic Impact Fiscal
    • “total timber volume affected by this rule is less than 0.5 percent of total United States production”
    • “projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year”
    • “expanding a road system already carrying a $6.9 billion maintenance backlog”
    • “certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected”
  • Forest Management Wildfire
    • “Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas”
    • “human-caused ignitions increase in abundance with proximity to roads”
    • “has not quantified the expected increase in ignitions from new road access or weighed it against the claimed reduction in wildfire hazard”

What it names

National Forests
Bridger-Teton National Forest
Roadless areas
Continental Divide National Scenic Trail

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Bridger-Teton National Forest is home to countless world-class trails, including the Continental Divide National Scenic Trail, which I use to enjoy the landscape and view wildlife. Bears, elk, moose, and many other species depend on that landscape staying whole. Rescinding the 2001 Roadless Area Conservation Rule would put all of that at risk, and the agency's own record gives me no confidence the proposal can withstand scrutiny. The Bridger-Teton is the western wall of the Greater Yellowstone Ecosystem, the largest intact temperate ecosystem in the world. Its 19 inventoried roadless areas total 1,417,499 acres. The elk herds that winter in the National Elk Refuge depend on summer range in these roadless mountains, and pronghorn running the longest land migration in North America funnel through this forest. The agency's own science shows that elk avoid areas near roads and select habitat away from them, and that elk survival rates rose during a road closure and fell again when the gates were removed. For grizzly bears, the DEIS quotes the federal recovery plan directly: the increased contact and conflict that come with open roads in grizzly habitat can ultimately end in grizzly mortality, and shooting, habituation and food reward all increase with the use of even secondary unpaved roads. For moose, the DEIS notes they are drawn to road corridors for road salt, which increases human-moose interactions and conflict. Losing the roadless character of the Bridger-Teton would fracture exactly the uninterrupted habitat these species require. I ask the agency to explain, specifically, how the road expansion this rescission enables is compatible with the wildlife impacts its own analysis documents. Our public lands should be managed in the national interest, and the overwhelming public support during the scoping period of this proposal demonstrates exactly where the national interest currently lies. The economics do not point the other way. The agency's record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency must reconcile that finding with its own Cost Benefit Analysis, which projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million, and it must explain how an action whose own analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog. The small-business certification compounds the problem. "The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year." That certification is reached by spreading losses across every small firm in the sector nationally rather than assessing the guides and outfitters actually holding permits in places like the Bridger-Teton. The agency should withdraw the certification and assess impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. The fire data cuts against the proposal as plainly as the economic data. "Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014–2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads." The agency has not quantified the expected increase in ignitions from new road access or weighed it against the claimed reduction in wildfire hazard. It must do so before finalizing this rule. Finally, "The proposal solicits 'any reliance interests in the current rule that could be affected by this proposal' (91 FR 53830-31), and the Cost Benefit Analysis weighs none." This comment is one such interest. My use of the Continental Divide National Scenic Trail and the wildlife habitat it passes through has been shaped by the protections this rule provides. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before it can lawfully change course. Sincerely, Claire Cutler Denver, Colorado

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