Comment Analysis · Docket FS-2025-0001

FS-2025-0001-274219

Opposes rescissionA2 moderateSubstance 13/24Owed an answerPosted August 27, 2026 On Regulations.gov

In short: The comment places on the record specific data points from the agency's own prior findings and DEIS/FEIS documents that contradict the proposal's justification for rescinding the Roadless Rule based on wildfire risk and administrative burden, while also documenting a specific reliance interest in the existing protections.

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

Recreation Tourism Public Use
- “getting further away from civilization and crowds”
- “Abolishing roadless areas and allowing ATVs and dirt bikes everywhere completely ruins what makes them worth visiting”
- “I have planned repeated fall trips into the Angel Peak North roadless area”
- “lost recreation benefit at a minimum of $6.1 million per year”
Wildlife Habitat
- “supports Chinook salmon, steelhead, bull trout, wolverine, mountain goat, bighorn sheep, and gray wolf”
- “verified species there include Lahontan cutthroat trout, greater sage-grouse, pygmy rabbit, and elk”
- “each roadless range rises from the Great Basin like a sky island with its own ecology”
- “irretrievable values at risk”
Forest Management Wildfire
- “more than 90 percent of wildland fires are the result of human activity”
- “ignitions are almost twice as likely to occur in roaded areas as they are in roadless areas”
- “Opening these landscapes to roads and motorized access does not reduce fire risk”
- “reconcile the rescission with the ignition data in its own DEIS Table 21”
Governance Policy Process
- “The agency should withdraw the certification and assess the small entities actually operating”
- “I ask that it identify and assess the reliance interests described in the record”
- “The agency has not identified which burdens those exceptions fail to address”
- “quantify those claimed burdens on the record rather than assert them”

What it names

National Forests: Humboldt-Toiyabe National Forest Salmon-Challis National Forest
Roadless areas: Angel Peak NorthBorah Peak

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The entire point of getting out into nature is getting further away from civilization and crowds. I hike in national forests, particularly roadless areas, and I have done it in two states that have shaped how I think about this proposal. I lived in Idaho for six years. I summited Borah Peak (a roadless area) just a few years ago and I remember how special it was making that climb and gazing down at unencumbered wilderness to the north and south. I now live in Las Vegas, and I was just up hiking in the Angel Peak area (also inventoried as roadless) last week. It is beautiful, and there are hardly any properly protected roadless areas in national forest around here anyway… southern Nevada is not exactly known for vast woodlands. I am going back again and again in the fall to bag the smaller summits around Angel Peak. Our public land should be managed for now and for our children's children. Abolishing roadless areas and allowing ATVs and dirt bikes everywhere completely ruins what makes them worth visiting. I already see plenty of drunk idiots on Razors nearer to the accessible roads, starting illegal campfires and littering everywhere. I do not want that driven up into roadless backcountry. If you remove the roadless rule, the dregs of society will come for the Lost Rivers backcountry around Borah Peak. The Borah Peak roadless area covers more than 130k acres in the Salmon-Challis National Forest. That NF contains the largest roadless complex outside of designated wilderness in the lower 48, and it supports Chinook salmon, steelhead, bull trout, wolverine, mountain goat, bighorn sheep, and gray wolf. The Angel Peak North roadless area covers 12,577 acres in the Humboldt-Toiyabe National Forest, the largest national forest in the lower 48, where each roadless range rises from the Great Basin like a sky island with its own ecology, its own water, its own wildlife. The Humboldt-Toiyabe holds 354 inventoried roadless areas totaling 3,383,849 acres, and verified species there include Lahontan cutthroat trout, greater sage-grouse, pygmy rabbit, and elk. Stop trying to ruin what little we have. The proposal justifies rescission partly on wildfire and fuels management grounds. That argument contradicts the agency's own findings. According to the Forest Service, "more than 90 percent of wildland fires are the result of human activity, and ignitions are almost twice as likely to occur in roaded areas as they are in roadless areas (USDA Forest Service 1998, 2000)." Opening these landscapes to roads and motorized access does not reduce fire risk. It imports the ignition sources the agency's own data identify. I ask that the agency explain why this proposal departs from those prior findings and reconcile the rescission with the ignition data in its own DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The agency also claims administrative burden justifies rescission, but its own record states: "It makes little fiscal or environmental sense to build additional roads in inventoried roadless areas that have irretrievable values at risk when the agency is struggling to maintain its existing extensive road system (FEIS Vol. 1, 1-5 and 3-22)." The rule as written already contains exceptions for public health and safety, existing mineral leases, and community wildfire protection. The agency has not identified which burdens those exceptions fail to address. I ask that it do so specifically, and that it quantify those claimed burdens on the record rather than assert them. The proposal's regulatory flexibility analysis certifies no significant impact on small entities. The agency's own CBA analyzes lost recreation benefit at a minimum of $6.1 million per year and names outfitters, guides, and tour operators among the affected parties, yet the certification is reached by spreading the $9 million annual expenditure loss across every small firm in the sector nationally (no case-by-case analysis whatsoever). The analysis even concedes some firms may lose these receipts. That is not a no-impact finding. The agency should withdraw the certification and assess the small entities actually operating in the potentially affected roadless areas, not the national average firm. Finally, the proposal itself 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. I have planned repeated fall trips into the Angel Peak North roadless area in the Humboldt-Toiyabe based on the protections the 2001 rule provides. That is a reliance interest. The agency invited these comments and must weigh what it receives. I ask that it identify and assess the reliance interests described in the record before reaching any final decision. Thanks, Maxwell Erickson North Las Vegas, NV