Comment Analysis · Docket FS-2025-0001

FS-2025-0001-311828

Opposes rescissionA2 moderateSubstance 14/24Owed an answerPosted September 3, 2026 On Regulations.gov

In short: The comment establishes that the DEIS fails to support its causal premise regarding fuels treatment, inadequately analyzes road-related fire ignition risks, and presents an arbitrary range of alternatives that ignores the ecological consequences of state-line boundaries and the agency's $6.9 billion maintenance backlog.

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, Alternative.

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

Forest Management Wildfire
- “DEIS misattributes the cause of untreated fuels”
- “The 2001 rule already permits hazardous fuels reduction”
- “roads as a source of fire”
- “ignition probability declining steeply with distance from them”
Governance Policy Process
- “The range of alternatives is inadequate under NEPA”
- “The comment period is inadequate for the scale of this action”
- “arbitrary outcomes that contradict its own rationale”
- “One forest, one continuous set of watersheds... divided into two management regimes”
Water Quality Quantity
- “long-term erosion, sedimentation, invasive species, and watershed consequences”
- “continuous set of watersheds”
- “expanding and underfunded road network”
Recreation Tourism Public Use
- “regular weekend hiking destination”
- “user of forests this proposal affects”
- “These places are worth keeping in the condition they are in”

What it names

National Forests: Medicine Bow-Routt National Forest

Attachments

1 file. Counts as 1 — Counts as one: The attachments enclose no one else's submissions; the comment counts as one.

Own letter

The comment

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

I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. A longer version of this comment is attached. I am a private citizen and a user of forests this proposal affects. The Medicine Bow National Forest was my regular weekend hiking destination from 2020 to 2022. I made roughly six trips to the Manti-La Sal National Forest west of Monticello, Utah between 2017 and 2024. Both contain mapped inventoried roadless areas that this proposal would open to road construction and timber harvest. 1. The DEIS misattributes the cause of untreated fuels. The 2001 rule already permits hazardous fuels reduction in inventoried roadless areas. It restricts road construction, road reconstruction, and commercial timber harvest. It does not bar the fuels work the Department calls urgent. The Department's own figure, that only 5 percent of high-hazard roadless acreage has been treated since 2014, is offered as proof the rule is the obstacle. It shows the opposite. If treatment was permissible for 25 years and did not happen, the binding constraint was appropriations and agency capacity, not regulation. The DEIS should disclose how many fuels projects in inventoried roadless areas were actually denied, withdrawn, or narrowed because of the 2001 rule. Absent that record, the causal premise of this rulemaking is unsupported. 2. The DEIS does not adequately analyze roads as a source of fire. The proposal treats road access only as a suppression benefit. Roughly 89 percent of US wildfires are human-caused, and published research finds ignitions substantially more likely near roads, with ignition probability declining steeply with distance from them. Separate analysis finds that inventoried roadless areas have not burned at higher rates or severity than roaded national forest land. If roadless areas are not burning worse, and roads elevate ignition risk, the final EIS must weigh new ignitions created against suppression access gained and disclose the net effect. 3. The proposal produces arbitrary outcomes that contradict its own rationale. The Medicine Bow-Routt National Forest is a single administrative unit spanning the Wyoming and Colorado line. Under this proposal the Routt side retains protection under the 2012 Colorado Roadless Rule and the Medicine Bow side loses it. One forest, one continuous set of watersheds, wildlife corridors, and big game ranges, divided into two management regimes by a political boundary. The same occurs on the Caribou-Targhee across the Idaho line, and within the Manti-La Sal itself at the Utah and Colorado line. This is not local, context-specific decision-making. It is an artifact of which states petitioned for state-specific rules two decades ago. The DEIS should analyze the ecological consequences of bisecting contiguous roadless landscapes along state lines and explain how that result serves the stated purpose of this rulemaking. 4. The range of alternatives is inadequate under NEPA. A choice between full rescission and no action is not a reasonable range. The DEIS should analyze intermediate and more protective alternatives, including a targeted amendment permitting site-specific exceptions in the wildland-urban interface while retaining core protections, a funding and capacity pathway that achieves the Department's stated fuels objectives within the existing rule, and an alternative extending roadless protection to additional qualifying lands. 5. Irreversibility and the maintenance backlog. Road construction in a roadless area is an irreversible and irretrievable commitment of resources requiring disclosure under NEPA. Roadless character does not return on any human timescale. The agency carries a road and bridge maintenance backlog of approximately 6.9 billion dollars. The DEIS should explain how the agency intends to maintain new roads when it cannot maintain the roads it has, and should account for the long-term erosion, sedimentation, invasive species, and watershed consequences of an expanding and underfunded road network. 6. The comment period is inadequate for the scale of this action. Thirty days for a proposal affecting approximately 44.7 million acres falls well short of the 60 to 90 days customary for a Draft Environmental Impact Statement of this magnitude, and it materially limited my own ability to review the analysis. I join the request from members of Congress to extend it. Inventoried roadless areas are roughly 2 percent of the land area of the United States. They are what remains after a century of road building. The reason most national forests show no roadless areas on the map is that the roading already happened. These places are worth keeping in the condition they are in. I ask that the Department withdraw this proposal and retain the 2001 Roadless Area Conservation Rule. Respectfully submitted, Levi Wright