Comment Analysis · Docket FS-2025-0001

FS-2025-0001-533012

Opposes rescissionA3 weakSubstance 12/24Owed an answerPosted October 4, 2026 On Regulations.gov

In short: The comment documents that the agency's proposal to rescind the Roadless Area Conservation Rule contradicts its own findings on wildfire ignition rates and sediment loading, fails to account for specific local reliance interests and economic impacts in the Bridger-Teton and Shoshone forests, and lacks a reasoned explanation for how expanding a road system with a $6.9 billion maintenance backlog serves the public interest.

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

Wildlife Habitat
- “pronghorn running the longest land migration in North America funnel through here”
- “Grizzly bear, gray wolf, cutthroat trout, trumpeter swan, and sage grouse live in this forest”
- “To see it unprotected is to see it destroyed”
- “habitat of every creature around me at risk”
Water Quality Quantity
- “I drink well water from this land”
- “Removing these protections could contaminate it and the water around me”
- “325 municipal water intakes sit in watersheds containing affected roadless areas”
- “prevent sediment loading in the watersheds feeding wells and streams”
Forest Management Wildfire
- “Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires”
- “More roads mean more fires, and more fires put my home, my livelihood, and the habitat of every creature around me at risk”
- “reconcile the rescission with the ignition data in its own draft environmental impact statement”
- “far higher fire density on roaded land than inside the affected roadless areas”
Economic Impact Fiscal
- “The economic case for rescission does not hold up under the agency's own numbers”
- “recreation losses of at least $6.1 million a year”
- “net present value ranging from -$92 million to +$199 million”
- “expanding a road system with a $6.9 billion maintenance backlog”

What it names

National Forests: Bridger-Teton National Forest Shoshone National Forest
Roadless areas: Gros Ventre MountainsRocky Mountain

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 Area Conservation Rule, Docket FS-2025-0001 The Bridger-Teton National Forest is my home, literally. I live on a ranch surrounded by it, and I watch wildlife out my front door every day. I hike and camp throughout the Bridger-Teton, the Gros Ventre area, and the Shoshone National Forest. I have recently taken up fly fishing, which has given me another way to be present in this landscape. The 19 inventoried roadless areas of the Bridger-Teton total 1,417,499 acres. The Gros Ventre Mountains alone account for 106,418 acres of that. This is the western wall of the Greater Yellowstone Ecosystem, the largest intact temperate ecosystem in the world. The pronghorn running the longest land migration in North America funnel through here. The elk herds that winter in the National Elk Refuge depend on summer range in these roadless mountains. Grizzly bear, gray wolf, cutthroat trout, trumpeter swan, and sage grouse live in this forest. To see it unprotected is to see it destroyed. It is my home, but it is also our home. Two years ago I was nearly evacuated because a fire came close enough to make that a real possibility. This summer, one started two miles away. The agency's own record states: "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 frames road access as part of the solution to wildfire risk. That is not a reconciliation, it is a contradiction. More roads mean more fires, and more fires put my home, my livelihood, and the habitat of every creature around me at risk. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence and reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. I drink well water from this land. Removing these protections could contaminate it and the water around me, harming the people who live here and the wildlife that depends on the same sources. Across the Rocky Mountain region, which includes Wyoming, 325 municipal water intakes sit in watersheds containing affected roadless areas. The agency's own analysis has found that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. The scale of what is at stake here is not speculative; it is documented in the agency's own record. I ask the agency to address what specific measures, if any, would prevent sediment loading in the watersheds feeding wells and streams in the Bridger-Teton and Shoshone forests if the rule is rescinded. The economic case for rescission does not hold up under the agency's own numbers. The record states: "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 that marginal gain, the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year, recreation losses of at least $6.1 million a year, and a net present value ranging from -$92 million to +$199 million. The road system the agency would be expanding already carries a $6.9 billion maintenance backlog. Outfitters, guides, and tour operators are named in the DEIS as affected parties; their losses are booked in the analysis. Yet the regulatory flexibility analysis certifies no significant impact on small entities by spreading a $9 million annual expenditure loss across every small firm in the sector nationally rather than examining the businesses actually holding permits in these areas. The agency has not established that this action produces a net benefit, and it must explain how expanding a road system with a $6.9 billion maintenance backlog serves the public interest here. Finally, the proposal itself solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. I have built my life around this landscape under the protections the 2001 rule provides. My ranch, my water, my livelihood as I have described it, and my use of the Gros Ventre Mountains and the Bridger-Teton for camping, hiking, and fishing all reflect decisions made in reliance on those protections remaining in place. An agency that invites reliance interest comments and then prices none of them into its analysis has not changed course in a reasoned way. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. Sincerely, Sydney J Moran, WY