Comment Analysis · Docket FS-2025-0001

FS-2025-0001-542646

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

In short: The comment places on the record specific deficiencies in the agency's analysis regarding wildfire ignition data (DEIS Table 21), financial feasibility (maintenance backlog vs. budget), and legal authority (Tenth Circuit holding on Organic Act/MUSYA), while identifying specific roadless areas in the Bighorn, Custer, and Gallatin National Forests and requesting reconciliation of the proposal with the agency's own prior findings and data.

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

Recreation Tourism Public Use
- “Spending time in nature is my way to appreciate God's good work”
- “I hike and camp with family and loved ones”
- “These are the places my child deserves to know”
- “They deserve to appreciate them in the way you only can from the saddle of a horse, or the satisfaction after a long hike”
Forest Management Wildfire
- “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 agency's own data says roads make their work more dangerous and more frequent”
- “reconcile the rescission with the ignition data in DEIS Table 21”
Wildlife Habitat
- “sheltering grizzly bear, Yellowstone cutthroat trout, wolverine, elk, and bighorn sheep”
- “The ecosystems these roadless areas support are critical, not only to wildlife but to us human animals”
- “local decision-making can incrementally erode nationally significant roadless values”
Water Quality Quantity
- “325 municipal water intakes sit in watersheds containing affected roadless areas”
- “Clean fresh water is the direct source of life for towns”

What it names

National Forests: Bighorn National Forest Custer National Forest
Roadless areas: Bear RocksBruce MountainCloud Peak ContiguousGrommund CreekHideout CreekLittle GooseLost Water CanyonLost Water Canyon RnaPiney CreekRock CreekRocky MountainSibley LakeWalker Prairie
Law cited: 28 U.S.C. Section 1291

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Spending time in nature is my way to appreciate God's good work. I hike and camp with family and loved ones. I share these places with my young child. I am filing this comment in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001) because what is at stake here is not abstract. The Bighorn National Forest in Wyoming holds inventoried roadless areas I care about directly: Piney Creek, Little Goose, Rock Creek, Walker Prairie, Grommund Creek, Sibley Lake, Bruce Mountain, Cloud Peak Contiguous, Bear Rocks, and Hideout Creek, together spanning hundreds of thousands of acres. Lost Water Canyon and Lost Water Canyon RNA in the Custer National Forest are in that same picture. These are the places my child deserves to know. The agency justifies this rescission in part on wildfire and fuels management grounds, and on that point the agency's own record answers the question directly. The DEIS 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." I think of the brave men and women who fight out of control wildfires. The agency's own data says roads make their work more dangerous and more frequent. The agency must explain why the proposal departs from this and must reconcile the rescission with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The financial logic of this proposal does not hold up under the agency's own numbers. The agency's record acknowledges 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." The most important thing is to take care of what we have first. If there is no money for maintenance, there is absolutely no money for anything new. The agency already carries a $6.9 billion road maintenance backlog against a road budget of roughly $73 million a year. The agency must reconcile the proposal with its own cost-benefit analysis. The proposal argues that state-by-state management can replace a national rule. The agency's own record quotes its prior position that the national rule embodied an "inflexible 'one-size-fits-all' nationwide rulemaking approach," 70 Fed. Reg. at 25,656, yet the Ninth Circuit rejected the state-by-state replacement that followed from exactly that reasoning. The agency has already made this argument, tried this approach, and lost. I want the agency to address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and to explain how this proposal avoids the deficiencies the Ninth Circuit identified the last time a national rule was traded for state petitions. The proposal also argues that the 2001 rule exceeded statutory authority. The Tenth Circuit addressed that question and held: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The court found the rule within the authority Congress granted under the Organic Act and MUSYA, and found it did not create de facto wilderness. The agency must address that holding and state plainly on the record what legal basis supports a contrary position now. As parents, we strive to give our kids more than we had. Wanting the best for our children is not only about college funds or belongings. It’s about their protections, their safety, their freedom. They deserve to know and see these untouched places. They deserve to appreciate them in the way you only can from the saddle of a horse, or the satisfaction after a long hike. The Custer and Gallatin units form the northeastern wall of the Greater Yellowstone Ecosystem, sheltering grizzly bear, Yellowstone cutthroat trout, wolverine, elk, and bighorn sheep. Across the Rocky Mountain region, 325 municipal water intakes sit in watersheds containing affected roadless areas. Clean fresh water is the direct source of life for towns. The ecosystems these roadless areas support are critical, not only to wildlife but to us human animals. The agency held more than 600 public meetings and took 1.6 million comments to write this rule. It has held none to undo it. My child should inherit more of these places, not fewer. Sincerely, A Proud Citizen of this Good Country