Comment Analysis · Docket FS-2025-0001

FS-2025-0001-274465

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

In short: The comment places on the record specific data from the agency's own DEIS and cost-benefit analysis demonstrating that the proposed rescission lacks a net economic benefit, contradicts the agency's own findings on wildfire risk associated with roaded lands, and fails to properly assess impacts on local small businesses and existing regulatory exceptions.

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

Economic Impact Fiscal
- “great waste of taxpayer dollars”
- “net present value range spanning -$92 million to +$199 million”
- “road system this proposal would expand already carries a $6.9 billion maintenance backlog”
Forest Management Wildfire
- “Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “reconcile its stated rationale for rescission with its own ignition data”
Recreation Tourism Public Use
- “recreation losses of at least $6.1 million a year”
- “outfitters, guides, and tour operators operating in these areas will be affected”
- “lost recreation benefit at a minimum of $6.1 million a year”
Wildlife Habitat
- “damage it has caused to wildlife”
- “watched what roads do to this landscape”

What it names

National Forests: Targhee National Forest
Roadless areas: West Slope Tetons

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 The land I am writing about is land I own, in common with millions of other Americans, and I live on the west slope of the Tetons in Idaho. I know the sorry history of logging here and the damage it has caused to wildlife, and for what? The vast majority of trees cut for lumber are already grown on private land. Logging public land, where the value of the timber harvest is far less than the cost to the government of enabling it, is a great waste of taxpayer dollars. Talk about waste, fraud and abuse. This proposal to rescind the 2001 Roadless Area Conservation Rule deserves none of the agency's stated justifications, and I oppose it fully. The Forest Serive's own record states: "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." This confirms what I have long argued. There is no meaningful national supply case for opening these lands. The proposal claims economic and employment benefits, but the agency's own cost-benefit analysis projects only $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year, and a net present value range spanning -$92 million to +$199 million. The road system this proposal would expand already carries a $6.9 billion maintenance backlog. How does an action whose own analysis cannot establish a net benefit justify that expansion? The agency must address this question directly in its final record. The West Slope Tetons roadless area adjacent to where I live covers 47,448 acres in the Targhee National Forest. Wyoming holds 116 inventoried roadless areas totaling 3,243,958 acres. I have watched what roads do to this landscape, and the agency's own analysis tells the same story about fire. The record 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." The proposal justifies rescission partly on wildfire and fuels management grounds, yet this finding sits in the agency's own draft environmental impact statement. The agency must reconcile its stated rationale for rescission with its own ignition data, specifically DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas, and explain the departure from its prior findings. The Forest Service claims the rule imposes administrative hardship, but the rule as written already provides relief. It "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. § 294.12(b)(1),(3)." Exceptions for public health and safety, existing mineral leases, and community wildfire protection are already there. The agency has not identified which specific burdens fall outside those existing exceptions. It should do so, with numbers attached, before proceeding further. Finally, the regulatory flexibility analysis certifies no significant impact on small businesses while the record shows outfitters, guides, and tour operators operating in these areas will be affected. The proposed rule itself acknowledges this: "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 certification was reached by spreading an estimated loss across every small firm in the sector nationally rather than examining the firms actually holding permits in the affected roadless areas. The agency should withdraw that certification and conduct a proper assessment of the small entities actually operating here, not the national average firm. I file these comments under Docket FS-2025-0001 and ask that the agency address each point in its final decision. Sincerely, Frederick Johnson Tetonia, Idaho