Comment Analysis · Docket FS-2025-0001

FS-2025-0001-279910

Opposes rescissionA1 strongSubstance 13/24Owed an answerPosted August 28, 2026 On Regulations.gov

In short: The comment documents specific deficiencies in the DEIS regarding the lack of projected sediment delivery, the failure to identify enforceable drinking water provisions equivalent to 36 CFR 294.12/294.13, and the failure to apply cited fragmentation statistics to the 40.1 million affected acres, while requesting site-specific analysis for named roadless areas in Wyoming.

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

A1 strong: Must be answered — it names the law.

Owed an answer on Analytical gap, Legal.

Standard dismissals it defeats

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.
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.
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.

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.
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.

Topics

Water Quality Quantity
- “harmful effects of development and climate change on the waterways”
- “less water, less fish”
- “Road sediment is quantified and then set aside”
- “Twenty-four million people's drinking water is asserted away”
Recreation Tourism Public Use
- “I hike and fish to escape from people”
- “enjoy time outdoors without the sounds of motorized vehicles”
- “enjoy the outdoors in as pristine of a manner as is possible”
- “plenty of other areas people can take their vehicles”
Environmental Protection Biodiversity
- “wildlife pushed into other areas”
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
- “Good fishing depends on intact, connected watersheds, not fragments”
- “effects of the road construction and timber harvest it would newly allow”
Legal Regulatory Framework
- “ask that the agency disclose and analyze the site-specific environmental consequences”
- “identify, forest by forest, which plan provisions are equivalent to 36 CFR 294.12 and 294.13”
- “analyze in the DEIS an alternative that retains the 2001 rule's protections”
- “provide a reasoned explanation for it on the record”

What it names

National Forests: Bighorn National Forest Shoshone National Forest
Roadless areas: Bear RocksBruce MountainDevils CanyonHideout CreekHorse Creek Mesa
Law cited: 36 CFR 294.12

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 have fished and explored roadless areas such as those found in the Bridger Teton National Forest, the Bighorn Canyon National Recreation Area and the Shoshone National Forest. I have already seen the harmful effects of development and climate change on the waterways in these areas like less water, less fish, and wildlife pushed into other areas. Encouraging more development and motorized travel will make it even worse. I hike and fish to escape from people and enjoy time outdoors without the sounds of motorized vehicles and having to look at houses, mines and logging operations This area provides locals and visitors the ability to enjoy the outdoors in as pristine of a manner as is possible. There are plenty of other areas people can take their vehicles without having to wreck this area as well.. I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule, and specifically about these inventoried roadless areas: - Horse Creek Mesa (77,808 acres), Bighorn NF, Wyoming - Devils Canyon (37,416 acres), Bighorn NF, Wyoming - Bear Rocks (25,023 acres), Bighorn NF, Wyoming - Hideout Creek (10,096 acres), Bighorn NF, Wyoming - Bruce Mountain (5,417 acres), Bighorn NF, Wyoming - Shoshone 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: Road sediment is quantified and then set aside I fish for trout, and clean water over clean gravel is the whole of it. The agency states exactly what roads put into a stream: The DEIS: skid roads, trails, log landings and similar disturbances within timber sale areas are the main cause of soil erosion and “can contribute up to 90 percent of the sediment generated by timber sale activity.” The number appears in the document; no projection of sediment delivery follows it. I ask that the agency quantify projected sediment delivery to the more than 7,000 municipal intakes downstream of these areas. Issue 2: Twenty-four million people’s drinking water is asserted away I fish for salmon, and the water they need is the same water people downstream depend on. The agency names what is at stake and then asserts the protection away: Approximately 24 million people use water originating within the potentially affected roadless areas, through more than 7,000 municipal intakes, and less than 12 percent of these watersheds are currently impaired. The DEIS says forest plans address sources of public drinking water without identifying one enforceable provision. I ask that the agency identify, forest by forest, which plan provisions are equivalent to 36 CFR 294.12 and 294.13 for municipal watersheds. Issue 3: Fragmentation is quantified and not applied Good fishing depends on intact, connected watersheds, not fragments. I fish, and I raise this because the agency quantified fragmentation and then never applied it. The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. The number appears; no projection across the 40.1 million affected acres follows. I ask that the agency apply the cited fragmentation range to the 40.1 million acres of potentially affected environment. 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, Eric Robirds Powell, WY