Comment Analysis · Docket FS-2025-0001

FS-2025-0001-550283

Opposes rescissionA2 moderateSubstance 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 density (citing DEIS Table 21), grizzly bear mortality risks (citing the federal grizzly recovery plan), and small entity economic impacts (citing the Cost Benefit Analysis), while requesting the adoption of a 'no action alternative' to preserve the 2001 Roadless Rule.

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 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.
  • 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

  • Recreation Tourism Public Use
    • “Challenging myself with survival in the wild is an instrumental part of my fulfilled life”
    • “I walk the wilderness to connect with my innermost human spirit”
    • “I do not want to be among the last Americans to experience wilderness”
    • “I strongly advocate for a formal, affirmative policy for wilderness areas of 'Keep it Wild'”
  • Water Quality Quantity
    • “form the headwaters for rivers flowing to the Connecticut, the Merrimack, and the Saco”
    • “drinking water for communities across New Hampshire, Vermont, and Massachusetts”
    • “Roads change what a watershed delivers downstream”
    • “explain to the communities drawing from these headwaters what standard it applied”
  • Wildlife Habitat
    • “increased contact and conflict that come with open roads in grizzly habitat can ultimately end in grizzly mortality”
    • “shooting, habituation and food reward all increase with the use of even secondary unpaved roads”
    • “contributes the western extension of the largest intact temperate ecosystem in the world”
  • Forest Management Wildfire
    • “Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas”
    • “human-caused ignitions increase in abundance with proximity to roads”
    • “road access could increase the number and frequency of wildfires”
    • “quantify the expected increase in human-caused ignitions from new road access”

What it names

National Forests
Bridger-Teton National ForestDixie National ForestSalmon-Challis National ForestSan Juan National ForestWhite Mountain National Forest
Roadless areas
Casto BluffWhite Mountain

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Challenging myself with survival in the wild is an instrumental part of my fulfilled life. I walk the wilderness to connect with my innermost human spirit, and God is with me. I have personally experienced the freedom of mind and faith that our American wilderness areas afford to any hiker, hunter, angler, sportsman, or salvation-seeker, and I return to these untrammeled places again and again: the Kilkenny and Presidential-Dry River Extension units of the White Mountain National Forest in New Hampshire, the 1,483,000-acre Bob Marshall Wilderness Complex in Montana, the Bridger-Teton National Forest in Wyoming, the Hermosa and West Needle units of the San Juan National Forest in Colorado, Casto Bluff in the Dixie National Forest in Utah, and the Salmon-Challis National Forest in Idaho. These are not abstractions. They are where I seek what footpaths have always made possible. The creation of a road where none has been needed before, where footpaths have always sufficed, would greatly diminish the legacy I wish to leave to my children and generations to come. I do not want to be among the last Americans to experience wilderness in all these unique areas of our great country. The White Mountain National Forest exists in part because of what happened when New England's mountains were clearcut, a history that moved Congress to pass the Weeks Act of 1911. Its 16 inventoried roadless areas total 240,669 acres and form the headwaters for rivers flowing to the Connecticut, the Merrimack, and the Saco, drinking water for communities across New Hampshire, Vermont, and Massachusetts. Roads change what a watershed delivers downstream. The agency should explain to the communities drawing from these headwaters what standard it applied to their interest in this rescission. The Bridger-Teton contributes the western extension of the largest intact temperate ecosystem in the world with 1,417,499 acres of inventoried roadless land. The DEIS quotes the federal grizzly recovery plan: the increased contact and conflict that come with open roads in grizzly habitat can ultimately end in grizzly mortality, and shooting, habituation and food reward all increase with the use of even secondary unpaved roads. I ask the agency to explain, for the record, how it weighs that finding against the proposed rescission. The agency's own fire data does not support its direction. "Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads." The effects analysis concedes that road access could increase the number and frequency of wildfires. The agency should quantify the expected increase in human-caused ignitions from new road access and weigh it honestly against the claimed reduction in wildfire hazard before proceeding. The regulatory flexibility analysis reaches its no-impact conclusion by spreading expenditure losses across every small firm in the sector nationally rather than assessing the outfitters and guides actually holding permits in the affected areas. Yet "The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year." The agency should withdraw that certification and assess the impact on the small entities actually operating in these areas, not the national average. Finally, the agency both restricts and expands its own scope in the same document. "The proposed rule concedes that subsequent revisions 'could increase the area where timber harvest and road construction would be allowed,' declares changes to plans beyond the scope of the proposal, and then requests public comment on them (91 FR 53830)." That revision scenario, including any expansion of timber harvest area, must be analyzed as part of this action, not deferred. The agency should identify and weigh ALL reliance interests described in the comments it receives before it acts. I have worked alongside NFS crews to clear trails in the Bob Marshall Wilderness for better access by hikers and horseback riders, never for vehicles. And I have felt pride when making a new friend because I helped his or her passage on horseback through the Bob. I strongly advocate for a formal, affirmative policy for wilderness areas of "Keep it Wild". I strongly oppose removing the Roadless Rule and ask for the Forest Service to adopt a "no action alternative" to keep the Rule intact, as it was written in 2001. I urge you to conserve our nation's roadless forests and keep the Roadless Area Conservation Rule in place. Sincerely, David A. Carre Wayne, Pennsylvania

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