Comment Analysis · Docket FS-2025-0001

FS-2025-0001-337647

Opposes rescissionA3 weakSubstance 9/24Owed an answerPosted September 8, 2026 On Regulations.gov

In short: The comment establishes that the proposed rescission of the 2001 Roadless Area Conservation Rule fails to adequately analyze the tradeoffs between road construction and wildfire risk, ignores the specific economic and wildlife habitat impacts on gateway communities like Dubois, and is procedurally disproportionate given the historical public support for the 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

A3 weak: Substantive, but easier to set aside.

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.
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.
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.
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
- “functioning wildlife habitat, not idle land”
- “intact, unroaded security habitat and migration corridors”
- “Road construction fragments exactly the kind of large, connected blocks of habitat”
Governance Policy Process
- “removes a floor, not a ceiling”
- “forest plans are revised on decade-plus timelines, are chronically under-resourced”
- “not proportionate to the scale of public engagement”
Recreation Tourism Public Use
- “recreation economy of this part of Wyoming”
- “depend economically on hunting, fishing, and backcountry recreation”
- “value of these areas to outfitting, guiding, and recreation-based local economies”
Forest Management Wildfire
- “wildfire-risk rationale does not obviously support road-building”
- “Building and maintaining new roads into roadless terrain to enable 'treatment' adds cost and ignition risk”
- “DEIS should be required to actually weigh that tradeoff”

What it names

National Forests: Shoshone National Forest

The comment

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

Public Comment — Docket FS-2025-0001 / RIN 0596-AD66 Re: Proposed Rescission of the 2001 Roadless Area Conservation Rule Submitted via Regulations.gov | Deadline: September 21, 2026 To the U.S. Department of Agriculture, Forest Service: I am submitting this comment in strong opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule. I live at the edge of the Shoshone National Forest near Dubois, Wyoming — my property sits directly at the human-wildlife interface, and the roadless backcountry behind it is not an abstraction to me. I serve on the board of a local land-use focused nonprofit and volunteer with our local water district. I am currently working through a separate special-use lease application with the Wyoming Office of State Lands and Investments for a nearby parcel, so I understand firsthand how much time, coordination, and local buy-in it takes to get land management decisions right — and how easily that process can be derailed or captured by whoever has the most resources to show up at the table. That is precisely my concern with this proposal. 1. The proposal removes a floor, not a ceiling — and local forest plans are not an adequate substitute. The 2001 Rule exists because forest-by-forest, project-by-project decisionmaking had already been tried and had not protected the last unroaded landscapes. Forest plans are revised on decade-plus timelines, are chronically under-resourced, and are far more exposed to short-term political and industry pressure at the local level than a national baseline standard. Pushing roadless management entirely into that process doesn't add local flexibility so much as it removes the one consistent backstop against project-by-project attrition of these areas, one decision at a time. 2. The wildfire-risk rationale does not obviously support road-building as the fix. The proposal and accompanying materials cite hazardous-fuels backlog in roadless areas as justification. But most human-caused ignitions occur near existing roads, and the Forest Service's own road system already carries a multi-billion-dollar deferred maintenance backlog. Building and maintaining new roads into roadless terrain to enable "treatment" adds cost and ignition risk of its own; the DEIS should be required to actually weigh that tradeoff rather than assume more road access nets out to lower fire risk. 3. Roadless areas are functioning wildlife habitat, not idle land. The country around Dubois depends on intact, unroaded security habitat and migration corridors for elk, bighorn sheep, and grizzly bear — species that define both the ecology and the recreation economy of this part of Wyoming. Road construction fragments exactly the kind of large, connected blocks of habitat that cannot be recreated once broken up. This is a direct, local, near-term consequence of the rule change, not a hypothetical one. 4. This reverses one of the most heavily vetted and broadly supported rules in agency history without a comparable process. The 2001 Rule was developed over roughly two years through more than 600 public hearings and drew 1.6 million public comments — more than any rule in the nation's history at the time — with more than 90% of commenters in favor of the rule. That level of support has not faded with time: in the 2025 scoping comment period on this very rescission, independent analysis found that over 99% of the comments submitted opposed repeal. Rescinding the rule in full, on a comment timeline this compressed and attached to a 333-page draft EIS, is not proportionate to the scale of public engagement this issue has consistently generated for 25 years. 5. The economic analysis should account for recreation-dependent communities, not just timber and fuels-treatment value. Dubois and similar gateway communities depend economically on hunting, fishing, and backcountry recreation that roadless designation directly protects. I ask that the final cost-benefit analysis be revised to quantify the value of these areas to outfitting, guiding, and recreation-based local economies, not solely the value unlocked by road access for timber and fuels treatment. Requested action: I ask USDA to withdraw the proposed rescission and retain the 2001 Roadless Rule. At minimum, if the agency proceeds, I request a substantially longer comment period given the length and complexity of the draft EIS, and a supplemental analysis addressing the wildlife connectivity, water quality, and recreation-economy impacts specific to roadless areas adjoining gateway communities like Dubois. Thank you for considering this comment. Tim Judson Dubois, Wyoming