Comment Analysis · Docket FS-2025-0001

FS-2025-0001-271185

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

In short: The comment establishes that the agency's analysis fails to assess site-specific environmental consequences and reliance interests for Phillips Ridge in the Bridger-Teton National Forest, specifically highlighting a contradiction between the small-business certification and the DEIS findings regarding outfitters and recreation benefits.

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, Alternative.

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

Recreation Tourism Public Use
- “hiking, camping, running and biking”
- “solitude, the peacefulness of being out in our natural spaces”
- “lost recreation benefit at a minimum of $6.1 million a year”
- “small outfitters and guides who work this same country”
Environmental Protection Biodiversity
- “keep the wilderness the wilderness”
- “risk further damage to the places we can't even maintain now”
- “The animals, the plants, the water - all of these things are preserved because people care to protect them”
- “effects of the road construction and timber harvest it would newly allow”
Water Quality Quantity
- “We see and feel the water changing”
- “Further development will exacerbate this”
- “the water - all of these things are preserved because people care to protect them”
Legal Regulatory Framework
- “small-business certification contradicts the analysis beside it”
- “Under Encino Motorcars and Regents, an agency changing course must assess the reliance interests”
- “ask that the agency disclose and analyze the site-specific environmental consequences”
- “provide a reasoned explanation for it on the record”

What it names

National Forests: Bridger-Teton National Forest
Roadless areas: Phillips Ridge

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 We are in the Bridger Teton NF and the Jedediah Smith Wilderness nearly every weekend - hiking, camping, running and biking. We go there for the beauty, the solitude, the peacefulness of being out in our natural spaces. We ride the South Valley trails from the Mike Harris Trailhead as well is trails at Grand Targhee. In general, I believe in going deeper not broader. Let's invest and take care in the infrastructure we have created. Let's maintain our existing trails and roads and keep the wilderness the wilderness. We don't want to spread already thin resources even thinner and risk further damage to the places we can't even maintain now. My kids are worried about their future. They are worried that the places they enjoy now won't be here for them in the future. I want to be able to tell them that the places we protect and care for now are safe, we protect them so that they have longevity and can be enjoyed long into the future. At 10 and 13 years old, they aren't sure that protections mean much. This is unfortunate, and we can do better. We paddle extensively in Grand Teton National Park. It's beautiful, peaceful and a family tradition. We see and feel the water changing. Further development will exacerbate this. After visiting this place for more than 20 years, we moved here. It means that much to us. We moved here because of the place, it's proximity to national forests, wilderness, national parks and the outdoors. Current legislation threatens this. We know that it is special, but it is only special because there are people who care about and steward its wildness. The animals, the plants, the water - all of these things are preserved because people care to protect them. Let's continue to do our part. I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule, and specifically about Phillips Ridge (10,108 acres), Bridger-Teton National Forest, Wyoming. I ask that the agency disclose and analyze the site-specific environmental consequences of the proposed rescission for each of these areas, including the effects of the road construction and timber harvest it would newly allow. I raise the following issues for the record and ask that the agency respond to each of them: Issue 1: The small-business certification contradicts the analysis beside it I hike and camp in these areas, and the small outfitters and guides who work this same country help people like me get out there. They deserve a real assessment. 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. The supporting regulatory flexibility analysis reaches its no-impact conclusion by spreading the $9 million annual expenditure loss across every small firm in the sector nationally, rather than assessing the outfitters and guides actually holding permits in the affected areas, and concedes some firms may lose these receipts. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. Issue 2: Reliance interests are invited and never assessed I plan trips into these areas year after year, counting on the protection that keeps them what they are. That reliance is exactly what the agency asked commenters to describe. 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. Under Encino Motorcars and Regents, an agency changing course must assess the reliance interests its prior policy created. This comment is such an interest. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one. I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule’s protections for the areas named above. Where this proposal rests on factual conclusions that differ from the agency’s own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record. Sincerely, Kristine Spence Driggs, Idaho