Comment Analysis · Docket FS-2025-0001

FS-2025-0001-555402

Opposes rescissionA3 weakSubstance 12/24Owed an answerPosted October 5, 2026 On Regulations.gov

In short: The comment establishes that the proposed alternatives fail to account for the federal deficit, the USFS maintenance backlog, and the specific ecological consequences of increased human presence (such as invasive weeds on the Shoshone NF), thereby supporting Alternative 1 over Alternative 3.

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

Economic Impact Fiscal
- “billions of dollars of deferred maintenance on public lands”
- “Our colossal federal deficit negatively impacts the economy”
- “adding to it by setting in motion any government action destined to require more spending strikes me as ludicrous and irresponsible”
- “The consequence of such action is sure to add to the federal deficit”
Environmental Protection Biodiversity
- “increased human presence impacting the flora and fauna”
- “spread of invasive weeds”
- “Native plant communities are adversely changed”
- “I cherish the scenery and wildlife of the Rocky Mountains”
Governance Policy Process
- “no reasonable accounting included in the proposal”
- “no distinction between the various uses of roads”
- “managing those consequences is not addressed in these proposed alternatives”
- “I support Alternative 1”

What it names

National Forests: Shoshone National Forest

The comment

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

I have three comments regarding the Proposed Alternatives. 1.Not all roads are equal. Roads built strictly for a timber harvest can be put to bed when that timber sale is complete. The logging company is responsible for maintenance and restoration as per the timber sale contract. Logging roads can and do recover, and as that happens wildlife move back in. I don’t know about wells and mines; perhaps the roads needed for those resource extractions are more damaging and last longer, but maintenance is required as per the mineral lease. Roads built for ATV’s and wheeled vehicles are different. The engineering, construction and maintenance of public roads on public lands are the responsibility of the taxpayer, and once new roads are open for public use it’s nearly impossible to close them down. The roads become an entitlement. 2.The billions of dollars of deferred maintenance on public lands must be considered alongside these alternatives. The non-commercial use most affected by roadless rules are ATV recreationists. Hunters and fishermen, hikers, and horseback riders are not requesting more roads. Opening previously roadless areas to ATV use requires roads, and roads require maintenance. The current maintenance backlog proves the USFS lacks funds and is unable to recruit skilled equipment operators needed to fully man the current road maintenance crews. Our colossal federal deficit negatively impacts the economy of our entire country, and adding to it by setting in motion any government action destined to require more spending strikes me as ludicrous and irresponsible. 3.In addition the direct cost of roads are the costs associated with increased human presence impacting the flora and fauna. There are consequences to increased human presence, and managing those consequences is not addressed in these proposed alternatives. There are many examples, but one which comes to mind immediately is the spread of invasive weeds. This is a severe problem on the Shoshone NF, yet nothing is being to control or prevent the spread which has accelerated in the past 10 years. Native plant communities are adversely changed, with negative consequences to wildlife, water quality, downstream agriculture, livestock grazing, and scenery. Managing the consequence of increased human presence requires effort, committed USFS employees, and more taxpayer dollars. None of which is provided for in the proposed alternatives. 4.CONCLUSION: I believe there is a need for resource extraction, particularly timber, from public lands. I understand the benefits of recreational use of public land to local communities. I wish Alternative 3 included accounting proving its adoption will not contribute to the national debt. However, since there is no reasonable accounting included in the proposal, and no distinction between the various uses of roads, I cannot. The consequence of such action is sure to add to the federal deficit rather than generate enough economic benefit to offset the cost to taxpayers. Therefore I support Alternative 1. My background, which may add a certain legitimacy to my opinion: I have been a resident of Wyoming since 1988, and live in close proximity to USFS land currently designated Roadless. My experience with USFS Roadless areas includes recreation (hiking, horse riding, back country skiing, hunting) and working (herding cattle for friends). I was a USFS employee in Utah and Wyoming on a timber crew burning slash piles in winter and planting seedlings in spring, on a trail maintenance crew, and checked grazing allotments. This is to say I have experienced USFS lands from multiple angles for more than 5 decades. I cherish the scenery and wildlife of the Rocky Mountains, not just game animals but the entire spectrum of fauna and flora, and the open space on which those animal and plant communities depend. I also value the people and economic health of rural communities, and recognize the benefits derived from multiple use public land – meaning timber and mineral extraction, livestock grazing, hunting, fishing and recreation -- not only for locals but for the entire population of the USA.