Comment Analysis · Docket FS-2025-0001

FS-2025-0001-543300

Opposes rescissionA2 moderateSubstance 10/24Owed an answerPosted October 4, 2026 On Regulations.gov

In short: The comment documents that rescinding the Roadless Area Conservation Rule will increase road access, leading to more wildfires and subsequent snow avalanche hazards in specific western locations like Blaine County, Idaho and the Wasatch Front, Utah.

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

A2 moderate: Hard to dismiss — it shows cause and effect.

Owed an answer on 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.
  • 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.

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.
  • 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

  • Forest Management Wildfire
    • “increase in roads within forest lands is directly correlated to an increase in wildfire activity”
    • “Wildfire impacts will increase in the western United States as a direct result of rescinding the roadless rule”
    • “number of wildland fire ignitions increase as humans gain road access”
  • National Security Public Safety
    • “increases hazards to recreational users, infrastructure, and in some western communities urban areas”
    • “This increase in hazard may result in the loss of life or property”
    • “greatly increased avalanche threats to roads, people and property”
  • Scientific Research Evidence
    • “Significant evidence exists that an increase in roads within forest lands is directly correlated to an increase in wildfire activity (Aplet et al., 2026)”
    • “A known but often overlooked result of wildfire is a correlated increase in snow avalanche activity (Campbell et al., 2019)”
    • “The United States Geological Survey (USGS) recognizes this threat”

What it names

National Forests
Sawtooth National Forest
Roadless areas
Warm Springs

Attachments

1 file. Counts as 1 — Counts as one: The attachments enclose no one else's submissions; the comment counts as one.

  • Own letter

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific place

Technical Comments on the Proposed Rescission of the 2001 Roadless Area Conservation Rule Submitted by: Avalanche Risk Solutions, LLC Docket: FS-2025-0001 RIN: 0596-AD66 Proposed Rule: Special Areas; Roadless Area Conservation Federal Register Citation: 91 FR 53827 Significant evidence exists that an increase in roads within forest lands is directly correlated to an increase in wildfire activity within those areas (Aplet et al., 2026) A known but often overlooked result of wildfire is a correlated increase in snow avalanche activity (Campbell et al., 2019). Mature forest acts as anchorage for snowpacks on steep hillsides in the western United States. Forests also have a slowing effect on avalanches that start above them and typically reduce the risk to people and structures at lower elevation. When this mature growth is eliminated through wildfire or cutting this anchoring effect is eliminated and new avalanche paths are created. This newly created avalanche terrain increases hazards to recreational users, infrastructure, and in some western communities urban areas. Urban infrastructure commonly exists below designated roadless areas. Prominent examples include the Wasatch Front of Utah; and Warm Springs Road in Ketchum, Idaho. This increase in hazard may result in the loss of life or property. An example of this increased hazard is Blaine County, Idaho. Wildfire activity in this area has fundamentally altered the avalanche hazard affecting the wildland/urban interface and thus greatly increased avalanche threats to roads, people and property. (Miller et al., 2023). The United States Geological Survey (USGS) recognizes this threat and has gone as far as publishing it on USGS.gov (pubs.usgs.gov/publication/70249585). There is a known and correlated increase in avalanche activity as a result of wildfire. It is recognized that the number of wildland fire ignitions increase as humans gain road access, far outweighing the benefit of increased firefighting response time. Wildfire impacts will increase in the western United States as a direct result of rescinding the roadless rule, and thus the avalanche hazards shall also. We recommend that the US Congress uphold the roadless rule on USFS lands and avoid compounding the problems from wildland fire and avalanches. -Ownership and Senior Avalanche Consultants of Avalanche Risk Solutions LLC David Richards Donald Sharaf Kiira Antenucci AVALANCHE RISK SOLUTIONS, LLC (801) 556-5615 INFO@AVALANCHERISKSOLUTIONS.COM References: Aplet, G. H., Hartger, P., & Dietz, M. S. (2026). Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. Fire Ecology, 22(8) Campbell, C., Gould, B., & Thumlert, S. (2019). Post Wildfire Analysis of Avalanche Hazard. The Avalanche Journal, 121 (Summer 2019), 22–25. [1] Miller, Z., Sykes, J., Guinn, M., VandenBos, B., Savage, S., and Peitzsch, E.H., 2023, Spatial extent of forested avalanche terrain impacted by wildfire across the Sawtooth National Forest, in Proceedings, International Snow Science Workshop 2023, Bend, OR, October 8-13, 2023, p. 272- 279. AVALANCHE RISK SOLUTIONS, LLC (801) 556-5615 INFO@AVALANCHERISKSOLUTIONS.COM

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