Comment Analysis · Docket FS-2025-0001

FS-2025-0001-274214

Opposes rescissionA2 moderateSubstance 15/24Owed an answerPosted August 27, 2026 On Regulations.gov

In short: The comment establishes that the agency's DEIS analysis fails to reconcile its wildfire rationale with its own ignition data in Table 21, fails to project the impact of a 13-75% biodiversity fragmentation range across 40.1 million acres, and omits population-level projections for elk 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
    • “watch birds and other wildlife”
    • “habitat fragmentation reduces biodiversity”
    • “elk survival rates increased during a road closure”
    • “elk avoid roads and select unroaded habitat”
  • Forest Management Wildfire
    • “wildfire rationale contradicts the agency's own data”
    • “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
    • “roads bring fire risk, not fire relief”
    • “letting that, and many other fires burn”
  • Environmental Protection Biodiversity
    • “largest intact temperate ecosystem in the world”
    • “maintain the maximum sustainable biodiversity and ecological integrity”
    • “40.1 million acres of potentially affected environment”
  • Recreation Tourism Public Use
    • “go into almost daily to hike”
    • “direct stake in what the agency decides”
    • “estimate effects on hunting opportunity”

What it names

National Forests
Bridger-Teton National Forest
Roadless areas
Wilderness Study Area

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 I live near the Bridger-Teton National Forest and the Palisades Wilderness Study Area, and go into almost daily to hike and watch birds and other wildlife. I have a direct stake in what the agency decides here, and I oppose the rescission of the 2001 Roadless Area Conservation Rule and ask the agency to address the specific failures in its analysis described below. The Bridger-Teton holds 19 inventoried roadless areas totaling 1,417,499 acres. It forms the western wall of the Greater Yellowstone Ecosystem, the largest intact temperate ecosystem in the world. The proposal's wildfire rationale contradicts the agency's own data. The DEIS states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." I lived through the Green Knoll fire some years ago. That fire was overdue, and I am glad that forest managers at the time recognized the importance of letting that, and many other fires burn. The agency's own ignition data point in the same direction the Green Knoll managers understood: roads bring fire risk, not fire relief. The agency must explain why the proposal departs from its own prior findings and must reconcile that departure with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. On biodiversity, the DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. That range is documented and then left floating, unconnected to the 40.1 million acres of potentially affected environment. This forest and our other wildlands should be managed to maintain the maximum sustainable biodiversity and ecological integrity possible. A fragmentation range that wide, applied across an area that large, demands a projection, not a citation. The agency must apply that range to the 40.1 million acres. Finally, on big game: the DEIS cites the finding that elk survival rates increased during a road closure and decreased when the gates were removed (Cole 1997), and that elk avoid roads and select unroaded habitat. The elk herds of the Bridger-Teton, including those whose summer range sits in these roadless mountains, are directly implicated. Nowhere in the document does the agency project population-level consequences or estimate effects on hunting opportunity. That gap must be filled before any final decision is made. Sincerely, Brot Coburn PO Box 1022 Wilson, Wyoming 83014

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