Comment Analysis · Docket FS-2025-0001

FS-2025-0001-476187

Opposes rescissionPosted September 23, 2026 On Regulations.gov

Not scored for substance: the comment does not clear the floor of substantive signal.

Topics

  • Recreation Tourism Public Use
    • “hunt, hike, ski, and ride my horses and mountain bike”
    • “writing about recreational opportunities on our national forests”
    • “providing hunting and fishing opportunites for millions of Americans”
  • Forest Management Wildfire
    • “IRAs [inventoried roadless areas] across western states NFS land are not associated with a significantly greater rate of burning”
    • “lack of evidence showing that lands designated as roadless burn at a greater rate than roaded areas”
    • “not associated with... a greater rate of moderate- and high-severity fire”
  • Wildlife Habitat
    • “provide key habitat for big game and other species”
    • “cold-water fisheries protection”
    • “benefits the Roadless Rule has bequeathed to America's people and wildlife”
  • Economic Impact Fiscal
    • “generated $24 billion in annual benefits in the lower-48”
    • “made a substantial portion of my income from writing about recreational opportunities”

What it names

National Forests
Bridger-Teton National Forest
Works cited
10.1111/csp2.70411

The comment

My name is Ted Kerasote and I live on the edge of the Bridger-Teton National Forest, where I hunt, hike, ski, and ride my horses and mountain bike. I've been a freelance nature, sports, and adventure travel writer since the 1970s and have made a substantial portion of my income from writing about recreational opportunities on our national forests. The Roadless Area Conservation Rule has not only augmented my subject matter, it has also generated $24 billion in annual benefits in the lower-48 (see Earth Economics: https://www.eartheconomics.org/news/roadless-rules?utm_source=gemini#:~:text=In%20an%20initial%20economic%20analysis%20of%20ecosystem,importance%20of%20continuing%20to%20protect%20these%20lands.) Moreover, these roadless areas provide key habitat for big game and other species as well as cold-water fisheries protection, providing hunting and fishing opportunites for millions of Americans. As for the argument that roadless areas cause more fires because their flammable timber can't be thinned, a recent study published in Conservation Science and Practice found that “IRAs [inventoried roadless areas] across western states NFS land are not associated with a significantly greater rate of burning—or a greater rate of moderate- and high-severity fire—relative to roadless or developed lands.” (See: “Roadless status under the Roadless Area Conservation Rule is not associated with increased wildfire in the US National Forest System,” (https://conbio.onlinelibrary.wiley.com/doi/10.1111/csp2.70411) In the light of all the benefits the Roadless Rule has bequeathed to America's people and wildlife—and the lack of evidence showing that lands designated as roadless burn at a greater rate than roaded areas—the Roadless Rule should be kept in place.

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