Comment Analysis · Docket FS-2025-0001

FS-2025-0001-367354

Opposes rescissionA3 weakSubstance 13/24Owed an answerPosted September 12, 2026 On Regulations.gov

In short: The comment establishes that the proposed rescission's reliance on 'local control' is undermined by the precedent of the Caribou-Targhee National Forest overriding state and local objections for the Grand Targhee Resort expansion, and that the projected economic benefits are negligible compared to the Forest Service's $8.6 billion maintenance backlog, while also documenting the commenter's 20-year residency in northwest Wyoming as a basis for standing.

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, 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.
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

Governance Policy Process
- “doesn't hold up against recent record”
- “federal appointees tied to the same partisan leadership”
- “require that any decision overriding a state agency's science-based objection... get elevated review”
- “not a Forest Supervisor's sign-off alone”
Wildlife Habitat
- “last intact habitat strongholds”
- “habitat for the isolated Teton Range bighorn sheep herd”
- “federally threatened whitebark pine”
- “degrade forage for wildlife and livestock alike”
Economic Impact Fiscal
- “USDA's own analysis projects $4.6–10.6 million a year in added timber revenue”
- “deferred maintenance backlog exceeded $8.6 billion”
- “roughly 0.12% of that backlog”
- “risk to 44.7 million acres... for a rounding error”
Forest Management Wildfire
- “Fire is a natural cycle here”
- “bark beetle is minor compared to the damage from invasive annual grasses”
- “spread largely by the very activities this rule expands”
- “invasive species accountability needs to be a first-order priority”

What it names

National Forests: Caribou-Targhee National Forest

The comment

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

Public Comment: Rescission of the 2001 Roadless Rule (Docket FS-2025-0001) I've lived in northwest Wyoming for 20 years, longer than anywhere else I've called home. When visitors ask what to do in Jackson, I tell them to get as far from the town square as possible. That pull toward solitude and wild ground isn't something anyone can promise you...it has to already exist, undeveloped. The wilderness access this administration's leadership enjoys is the kind money buys. Most Americans will never have that. What they can have is the last intact habitat strongholds that make this region a world-class wildlife refuge. Decommissioning roads in roadless areas is already illegal, and I take seriously the argument that rescission doesn't itself mandate new roads or logging...that's technically true. But "this approach prioritizes decision-making by local Forest Service officials informed by Tribes, State, and local communities" doesn't hold up against recent record. Authority under this rule sits with Forest Supervisors and Regional Foresters, federal appointees tied to the same partisan leadership issuing the rule, not county commissioners or the Wyoming legislature. This year, Caribou-Targhee National Forest approved a 694-acre, 28% boundary expansion for Grand Targhee Resort into habitat for the isolated Teton Range bighorn sheep herd and federally threatened whitebark pine. Wyoming Game and Fish (a non-partisan state agency) formally objected, calling it a violation of the forest plan and sensitive-species policy. Teton County Commission's preferred alternative had no expansion. The Forest Supervisor approved it anyway, just at reduced acreage. If that office overrides the state wildlife agency, two county Commissions, Grand Teton National Park, Teton Conservation District, and 1,200+ comments on one ski permit, "local control" won't hold the line on 44.7 million roadless acres either. I'd ask USDA to require that any decision overriding a state agency's science-based objection and the affected counties' stated position get elevated review and written public justification, not a Forest Supervisor's sign-off alone. The rule cites wildfire risk and insect/disease infestation as reasons for "active management." That's short-sighted. Fire is a natural cycle here, and bark beetle is minor compared to the damage from invasive annual grasses and other listed noxious species, spread largely by the very activities this rule expands: logging, grazing, and vehicle traffic. With the status quo strategy, treated acres often just regrow more weeds; untreated acres degrade forage for wildlife and livestock alike, at a cost of hundreds of millions of dollars, while operators pay permit fees worth pennies on the dollar with no meaningful efficacy on their repair obligation. If active management is the justification, invasive species accountability needs to be a first-order priority, not an afterthought to fire-risk framing. The economics don't clear the bar either. USDA's own analysis projects $4.6–10.6 million a year in added timber revenue from this rescission. The Forest Service's total deferred maintenance backlog exceeded $8.6 billion in FY2023, and the roads portion alone has been estimated above $8 billion, since the agency can only fund maintenance on about 20% of its 370,000 miles of road annually. Even the high-end revenue estimate is roughly 0.12% of that backlog, and there's no guarantee it flows to road maintenance at all. We are being asked to accept risk to 44.7 million acres of the last roadless ground in the country for a rounding error against the agency's own maintenance debt. Separately, this rule doesn't exist in a vacuum: recent budget actions cut $1.39 billion from the Forest Service, including $303 million in state/tribal partnership funding, alongside repeated attempts to mandate federal land sales. I'd ask USDA to disclaim any connection between this rescission and future land disposal, so it isn't read as one piece of a larger pattern. "Local control" should mean control by the people who live with the consequences, not a shift from Washington to a recently planted Forest Supervisor who gets to retire or transfer out of the community they just sold down the river.