Comment Analysis · Docket FS-2025-0001

FS-2025-0001-312644

Opposes rescissionA2 moderateSubstance 10/24Owed an answerPosted September 4, 2026 On Regulations.gov

In short: The comment documents that the DEIS analysis contradicts the rationale for rescinding the Roadless Rule by identifying specific adverse impacts, including increased wildfire ignition frequency, an unmanageable $6.9 billion road maintenance backlog, adverse effects on 327 threatened and endangered species, and jeopardized drinking water quality for 24 million Americans.

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

  • Water Quality Quantity
    • “protects local communities' drinking water supply from contamination”
    • “jeopardize the quality of drinking water for 24 million Americans”
    • “increased soil erosion, runoff, and sediment pollution”
    • “lives in a town that gets its water from a National Forest watershed”
  • Wildlife Habitat
    • “preserves critical wildlife habitat and migration corridors”
    • “adversely affect 327 threatened and endangered species”
    • “wildlife that feed our community and collective consciouses have habitat to thrive”
    • “species such as mule deer and elk”
  • Recreation Tourism Public Use
    • “As an outdoorsman, public-land user”
    • “areas where I've had some of my most formative experiences”
    • “preserves some of the few remaining wild landscapes in the western US”
    • “one of the reasons I live in Wyoming is because of our abundant roadless areas”
  • Forest Management Wildfire
    • “frequency and density of human ignitions are approximately four times lower in roadless areas”
    • “opening the door to more road building, we can therefore expect more, not less, wildfire-sparking ignitions”
    • “rescinding the Roadless Rule will decrease wildfire danger”
    • “Forest Service has an existing road maintenance backlog”

What it names

National Forests
Bridger-Teton National ForestMedicine Bow-Routt National Forest
Roadless areas
Sheep Mountain

The comment

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

As an outdoorsman, public-land user, taxpayer, and Wyomingite, I am wholeheartedly opposed to rescinding the Roadless Rule. I urge the Forest Service to choose the No Action alternative outlined in the Draft Environmental Impact Statement (DEIS). In Wyoming, the Roadless Rule protects local communities’ drinking water supply from contamination, preserves critical wildlife habitat and migration corridors for species such as mule deer and elk, and is central to our way of life. Roadless areas are a dwindling resource in the lower 48, and one of the reasons I live in Wyoming is because of our abundant roadless areas. From the Sheep Mountain Roadless Area on the Medicine Bow-Routt National Forest, to the Spread Creek – Gros Ventre River Roadless Area on the Bridger-Teton National Forest, these are areas where I’ve had some of my most formative experiences. Wyomingites will lose something that is a part of us all if roads are built in these areas. I am puzzled that the Forest Service’s Preferred Alternative (Alternative 2) is to rescind the Roadless Rule, when its own analysis in the DEIS points to such an action having many adverse effects. For example, the press release from Secretary Rollins draws heavily on the rationale that rescinding the Roadless Rule will decrease wildfire danger and promote forest health. However, the DEIS states that the frequency and density of human ignitions are approximately four times lower in roadless areas than they are on other lands that are part of the National Forest System (pg. 89). By wiping away the Roadless Rule and opening the door to more road building, we can therefore expect more, not less, wildfire-sparking ignitions. Further, the Forest Service has an existing road maintenance backlog of approximately $6.9 billion (pg. 43). How will the Forest Service maintain the new roads that will inevitably come from rescinding the Roadless Rule, especially with the staff and funding cuts the agency has seen in the past 18 months? The DEIS makes it clear that revenue from increased timber sales won’t cover the bill (pg. 45). The Forest Service’s preliminary biological assessment concluded that rescinding the Roadless Rule will adversely affect 327 threatened and endangered species (pg 25). National Forests are managed for multiple uses, which include wildlife and watershed protection. In this light, adverse impact to hundreds of threatened and endangered species is simply unacceptable. Any management decision that will cause this much harm to ecosystems needs to be rethought. Finally, the DEIS states that rescinding the Roadless Act will jeopardize the quality of drinking water for 24 million Americans (pg. 121) due to increased soil erosion, runoff, and sediment pollution (pg. 108). As someone who lives in a town that gets its water from a National Forest watershed, this action directly jeopardizes the health of my family and community. The Roadless Rule was overwhelmingly supported when it was created in 2001 (95% of the public comments were in favor of the rule at that time) and it remains popular today (99% of the public comments were in favor of the rule when the Forest Service first announced its intention to rescind the rule last year). I know why my friends and neighbors support the rule. It’s a common-sense measure that preserves some of the few remaining wild landscapes in the western US, it protects my drinking water, and it ensures that the wildlife that feed our community and collective consciouses have habitat to thrive. I’m a voter, a taxpayer, a Wyomingite, and I’m watching closely. I urge you not to rescind the Roadless Rule. Sincerely, James Mauch

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