Comment Analysis · Docket FS-2025-0001

FS-2025-0001-277119

Opposes rescissionA2 moderateSubstance 10/24Owed an answerPosted August 27, 2026 On Regulations.gov

In short: The comment places on the record specific deficiencies in the agency's analysis regarding the lack of projections for big game populations, hunter access, and biodiversity fragmentation across the affected environment, while citing specific economic data and regulatory exceptions to challenge the justification for rescinding the 2001 Roadless Area Conservation Rule.

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.

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
- “large roadless areas are essential to quality game habitat”
- “elk survival rates increased during a road closure”
- “elk avoid roads and select unroaded habitat”
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
Water Quality Quantity
- “watched those areas degrade when roads are extended into them”
- “Roads extended into roadless areas increase sedimentation and degrade those waters”
- “1,466 municipal water intakes sit in watersheds containing affected roadless areas”
- “address watershed protection on the merits”
Economic Impact Fiscal
- “The economic case for this rescission does not hold together”
- “timber revenue to the Forest Service of only $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year”
- “road system already carries a $6.9 billion maintenance backlog”
- “action whose own analysis cannot establish a net benefit justifies further expanding that backlog”
Recreation Tourism Public Use
- “I hike and camp in roadless areas outside designated wilderness”
- “hundreds of miles of motorized trails and less than 20 miles of nonmotorized trails”
- “recreation losses of at least $6.1 million a year”
- “The claim that the nonmotorized rule should be revoked to provide equal access is false”

What it names

National Forests: Sawtooth National Forest

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 Forty years of hunting in Idaho and Montana has taught me one thing clearly: large roadless areas are essential to quality game habitat. I also fish small streams and lakes, and I have watched those areas degrade when roads are extended into them. I hike and camp in roadless areas outside designated wilderness, including in the Cassia Ranger District of the Sawtooth National Forest, where there are hundreds of miles of motorized trails and less than 20 miles of nonmotorized trails. The claim that the nonmotorized rule should be revoked to provide equal access is false. I oppose the rescission of the 2001 Roadless Area Conservation Rule under Docket FS-2025-0001. The economic case for this rescission does not hold together. The agency's own 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 proposal is being advanced partly on timber economics and employment grounds, yet the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of only $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year, and a net present value spanning negative $92 million to positive $199 million. The road system already carries a $6.9 billion maintenance backlog. I ask that the agency reconcile the proposal with those numbers and explain how an action whose own analysis cannot establish a net benefit justifies further expanding that backlog. The proposal is also justified in part on permitting and administrative burden, but the rule as written already accommodates the activities the agency says it impedes. 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 already exist for existing mineral leases and community wildfire protection as well. I ask that the agency identify, by name and type, which specific permitting or administrative burdens are not already addressed by those exceptions, and that it quantify those burdens with actual data in the record. The small streams and lakes I fish depend on intact watersheds. Roads extended into roadless areas increase sedimentation and degrade those waters. Across the Intermountain region, which includes Idaho, 1,466 municipal water intakes sit in watersheds containing affected roadless areas. The fishing and drinking water implications of opening those watersheds to road construction receive no serious treatment in the proposal. I expect the agency to address watershed protection on the merits. The hunting I have done across Idaho and Montana for forty years depends on exactly the kind of undisturbed, unroaded country this rule protects. The agency's own document acknowledges the evidence: "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." Idaho alone holds 9,285,371 acres across 280 inventoried roadless areas. Despite citing this finding, the proposal projects no population-level effect on big game and no effect on hunter opportunity anywhere in the document. I ask that the agency project the effects of rescission on big game populations and hunter access before this action proceeds. The biodiversity evidence cited in the agency's own materials is similarly orphaned. "The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent." That range appears in the record and then goes nowhere. No projection applies it across the 40.1 million acres of potentially affected environment. The range is too wide and the stakes too large to leave unapplied. The agency must apply the cited fragmentation finding to the full extent of the affected environment and include that analysis in the final record. The Cassia Ranger District example I described is not an isolated case. Where motorized access already far outweighs nonmotorized opportunity, the access-equity argument for rescission does not apply. The agency should address that imbalance directly rather than treating rescission as a remedy for it.