Comment Analysis · Docket FS-2025-0001

FS-2025-0001-532956

Opposes rescissionA1 strongSubstance 14/24Owed an answerPosted October 4, 2026 On Regulations.gov

In short: The comment documents that the agency's proposal to rescind the Roadless Rule fails to reconcile its own data on increased human-wildlife conflict, higher fire density on roaded lands, and water quality risks with the justification for rescission, while also highlighting the lack of comparable public process and the economic uncertainty of the decision.

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

A1 strong: Must be answered — it names the law.

Owed an answer on Analytical gap, Evidence, Legal.

Standard dismissals it defeats

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.
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.
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.

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.
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.

Topics

Wildlife Habitat
- “wildlife are drawn into conflict when their habitat is disrupted”
- “removes the only landscape-scale protection for the habitat”
- “recovery of wildlife populations by preserving old-growth winter shelter”
Water Quality Quantity
- “relies on clean water for drinking, fishing, wildlife, and agriculture”
- “less than 12 percent of these watersheds are currently impaired”
- “skid roads, trails, log landings and similar disturbances within timber sale areas are the main cause of soil erosion”
Forest Management Wildfire
- “leaves these areas even more at risk for human-caused fire”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “reconcile that justification with DEIS Table 21, which reports far higher fire density on roaded land”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “recreation losses of at least $6.1 million a year”
- “Forest Service also carries a $6.9 billion maintenance backlog on its existing road system”

What it names

National Forests: Bridger-Teton National Forest
Law cited: 36 CFR 294.12

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequest

Re: Rescission of the Roadless Rule, Docket FS-2025-0001 The Owyhee River runs clear, and our family has fished it, along with the branches of the Boise and Snake Rivers, since our move to Idaho in the early 2000s. We hike and camp in the Sawtooth , Boise, and Payette National Forests. I grew up in Wyoming, and we return to the Bridger-Teton National Forest, where I have spent hours watching wildlife and spectacle of our wilderness areas. The outdoors is our church. Allowing roads to split and scar these areas is, to me, sacrilege. The Bridger-Teton holds 19 inventoried roadless areas totaling 1,417,499 acres and stands as the western wall of the Greater Yellowstone Ecosystem, the largest intact temperate ecosystem in the world. The wildlife I have watched there are drawn into conflict when their habitat is disrupted. The agency's own record acknowledges that wildlife are drawn to road corridors , which increases human interactions and conflict, and the rule's Tribal Summary Impact Statement credits the protection with recovery of wildlife populations by preserving old-growth winter shelter. Rescinding the rule removes the only landscape-scale protection for the habitat that keeps those animals where they belong. I ask the agency to explain, for each affected forest in the Bridger-Teton, and Idaho forests, how the proposal accounts for the documented increase in human-wildlife conflict that road corridors produce. Our family lives near Boise and accesses multiple forest areas. Eastern Idaho and Boise specifically bear the fallout of fire season: poor air quality, limitations on outdoor access, mudslides in forest areas tied to erosion after fire, and trail closures for safety. Increased road access, we believe, leaves these areas even more at risk for human-caused fire. The agency's own text confirms this: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal nonetheless justifies rescission partly on wildfire and fuels management grounds. The agency must reconcile that justification with DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas, and explain in plain terms why its own ignition data does not control the outcome here. We live in a region that relies on clean water for drinking, fishing, wildlife, and agriculture. The Pacific Northwest region, which includes Oregon where we fish the Owyhee, holds 1,522 municipal water intakes in watersheds containing affected roadless areas. The agency's own environmental impact statement states that "Approximately 24 million people use water originating within the potentially affected roadless areas, through more than 7,000 municipal intakes, and less than 12 percent of these watersheds are currently impaired." That figure is striking precisely because the rule is what holds impairment below 12 percent. The same document states that skid roads, trails, log landings and similar disturbances within timber sale areas are the main cause of soil erosion. I ask the agency to provide watershed-specific sediment delivery estimates for the municipal intakes downstream of each affected roadless area, and to identify, forest by forest, which plan provisions would be functionally equivalent to the protections currently carried by 36 CFR 294.12 and 294.13. The economic case for rescission is no stronger than the fire case. The agency's own record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against projected timber revenue to the Forest Service of $5.2 to $11.4 million a year, the agency's own Cost Benefit Analysis projects recreation losses of at least $6.1 million a year and a net present value spanning negative $92 million to positive $199 million. A range that wide cannot establish a net benefit. The Forest Service also carries a $6.9 billion maintenance backlog on its existing road system. The agency has not explained how expanding a system it cannot afford to maintain serves the public interest, and that question deserves a direct answer before this rescission proceeds any further. The rule being considered for rescission was developed through more than 600 public meetings and 1.6 million comments. No comparable process has been held to undo it. Many of our family traditions are centered around these forests. We want our children to take in and appreciate these places and understand that the forests are a place for reflection, healing, and wonderment. The agency should say plainly what it believes future generations are owed. Sincerely, Samantha Hamilton Boise, Idaho