Comment Analysis · Docket FS-2025-0001

FS-2025-0001-554101

Opposes rescissionA2 moderateSubstance 15/24Owed an answerPosted October 5, 2026 On Regulations.gov

In short: The comment establishes that the agency's proposal to rescind the Roadless Area Conservation Rule is internally inconsistent with its own DEIS data (Table 21) and Cost Benefit Analysis, fails to reconcile the wildfire rationale with prior findings on roaded lands, and contains a flawed small-business certification that ignores specific impacts on local outfitters in the Bridger-Teton National Forest.

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

Environmental Protection Biodiversity
- “verified populations of grizzly bear, gray wolf, elk, pronghorn, cutthroat trout, trumpeter swan, and sage grouse”
- “native plant communities I photograph in the Gros Ventre Mountains exist within a landscape whose connectivity cannot be managed piecemeal”
- “largest intact temperate ecosystem in the world”
- “pronghorn running the longest land migration in North America”
Forest Management Wildfire
- “Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “Opening its roadless areas to roads does not reduce fire risk by the agency's own measure”
- “reconcile the rescission with DEIS Table 21, which the agency's own draft environmental impact statement uses to report fire density data”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year”
- “Forest Service already carries a $6.9 billion maintenance backlog on its existing road system”
- “net present value spanning -$92 million to +$199 million”
Water Quality Quantity
- “325 municipal water intakes sit in watersheds containing affected roadless areas”
- “The 2001 rule protects all of it”
- “losses that follow [from road construction]”

What it names

National Forests: Bridger-Teton 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 favorite place for native plants, and the Gros Ventre Mountains are part of why. I camp and hike in the Bridger-Teton, hike in Grand Teton, and photograph the scenery and flowers there. Rescinding the 2001 Roadless Area Conservation Rule would put 1,417,499 acres of inventoried roadless land across 19 areas in the Bridger-Teton at risk of road construction and the losses that follow. This comment opposes the rescission in Docket FS-2025-0001. The agency's own record undermines the wildfire rationale for this proposal. The agency's prior findings state: "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 Bridger-Teton sits on the western wall of the Greater Yellowstone Ecosystem, the largest intact temperate ecosystem in the world. Opening its roadless areas to roads does not reduce fire risk by the agency's own measure. I ask that the agency explain why this proposal departs from those prior findings, and that it reconcile the rescission with DEIS Table 21, which the agency's own draft environmental impact statement uses to report fire density data by land type. The economic case for rescission is not established by the agency's own numbers. The record shows 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 agency's Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year, with a net present value spanning -$92 million to +$199 million. The Forest Service already carries a $6.9 billion maintenance backlog on its existing road system. I ask that the agency explain how an action whose own Cost Benefit Analysis cannot establish a net benefit justifies expanding that road system further, and that it address this reconciliation in the record. The proposal argues that state-specific approaches can replace a single national rule. The record contains the agency's own prior acknowledgment that the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's "inflexible 'one-size-fits-all' nationwide rulemaking approach." 70 Fed.Reg. at 25,656. That state-by-state approach was subsequently rejected in court. Wyoming holds 3,243,958 acres across 116 inventoried roadless areas, and the Bridger-Teton's roadless lands hold verified populations of grizzly bear, gray wolf, elk, pronghorn, cutthroat trout, trumpeter swan, and sage grouse. The native plant communities I photograph in the Gros Ventre Mountains exist within a landscape whose connectivity cannot be managed piecemeal without cumulative loss. The agency must address how this proposal avoids the legal deficiencies the Ninth Circuit identified when the agency last attempted to substitute state-by-state management for the national rule. The small-business certification accompanying this proposal is not consistent with the analysis beside it. 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. Outfitters and guides operating in the Bridger-Teton's roadless areas depend on the intact, unroaded character of places like the Gros Ventre Mountains. Spreading an annual expenditure loss across every small firm in the sector nationally, rather than assessing the permit holders actually operating in these areas, does not constitute a meaningful regulatory flexibility analysis. The certification should be withdrawn, and the agency should assess the impact on the small entities holding permits in the potentially affected roadless areas. The Bridger-Teton's roadless lands hold pronghorn running the longest land migration in North America and elk herds whose summer range feeds the National Elk Refuge. They hold the native plants I go there to photograph. Across the Rocky Mountain region, 325 municipal water intakes sit in watersheds containing affected roadless areas. The 2001 rule protects all of it. This rescission should not proceed.