Comment Analysis · Docket FS-2025-0001

FS-2025-0001-556978

Opposes rescissionA2 moderateSubstance 12/24Owed an answerPosted October 5, 2026 On Regulations.gov

In short: The comment documents specific deficiencies in the agency's analysis regarding wildfire ignition data, sediment and temperature impacts on water quality, and economic feasibility, while citing specific geographic locations and ecological data to request a withdrawal of the rescission proposal.

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
- “avid trail-runner, hiker, and camper”
- “find solitude in nature for peace and mental reset”
- “remote mountain bike trails”
- “Hiking, hunting, fishing, backcountry recreation, and the opportunity for solitude are legitimate public-land uses”
Wildlife Habitat
- “elk herds that winter in the National Elk Refuge depend on summer range”
- “grizzly bears, wolves, wolverines, and mountain goats roam”
- “animals do not need yet more human degradation of their natural spaces”
- “reducing egg survival, rearing densities, and growth of salmon”
Water Quality Quantity
- “building roads and the associated sediment runoff anywhere near waterways is one of the worst enemies of water habitat”
- “Removing riparian vegetation can raise stream temperatures”
- “Keep our clean water clean”
- “reconciles those documented sediment and temperature effects”
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”
- “rescinding the Roadless Rule could increase wildfire risk”
- “reconcile the rescission with the ignition data in its own DEIS”

What it names

Roadless areas: Big MountainGrande RondeSouth Fork

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 country I move through on foot, on a bike, and on water is the reason I am filing this comment. As an avid trail-runner, hiker, and camper across the western states, I rely on these landscapes for recreation, adventure, exercise, and solitude. In this day and age we humans need the ability more than ever to find solitude in nature for peace and mental reset. The 2001 Roadless Area Conservation Rule is a structural guarantee of that opportunity, and its rescission would eliminate something that cannot be rebuilt once it is gone. I travel long and far to discover remote mountain bike trails, particularly in the Uinta-Wasatch-Cache and Bridger-Teton areas of Utah and Wyoming. I also ride in Montana's Bitterroot, Flathead, Helena-Lewis and Clark, and Lolo national forests. These landscapes do not deserve to become more fragmented by new roads, logging, and mining. The Bridger-Teton alone holds 19 inventoried roadless areas totaling 1,417,499 acres, and it functions as the western wall of the Greater Yellowstone Ecosystem, the largest intact temperate ecosystem in the world. The elk herds that winter in the National Elk Refuge depend on summer range in those roadless mountains, and the agency's own record documents that elk survival rates rose during a road closure and fell again when the gates were removed. Rescission places that relationship directly at risk, and I ask the agency to address what road expansion in the Bridger-Teton and the Bitterroot's 405,883 roadless acres will mean specifically for elk populations that select habitat away from roads. The Bitterroot holds the Selway-Bitterroot Wilderness and its roadless buffer, described as the largest wild complex in the lower 48, where grizzly bears, wolves, wolverines, and mountain goats roam. These animals do not need yet more human degradation of their natural spaces. For whitewater paddling I am concerned about the South Fork Salmon River and its headwaters in Idaho, the Grande Ronde River in Oregon and Washington, and the Upper Chattooga River in Georgia and South Carolina, which runs through the Big Mountain and Ellicott Rock Roadless Areas and still feels remarkably wild. Anyone who has spent time near moving water understands that building roads and the associated sediment runoff anywhere near waterways is one of the worst enemies of water habitat. The agency's own analysis states that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Removing riparian vegetation can raise stream temperatures beyond what suits cold-water species, reducing egg survival, rearing densities, and growth of salmon. The affected area includes Essential Fish Habitat managed by NMFS. The agency should explain publicly how it reconciles those documented sediment and temperature effects with a proposal that would remove the principal regulatory barrier to new road construction across these watersheds. The wildfire justification offered for rescission contradicts what the agency has already put in its own record. "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." Having lived through wildfires in Colorado, I understand that rescinding the Roadless Rule could increase wildfire risk in all States by opening previously protected forests to more roads and human activity, potentially creating additional human-caused ignitions without guaranteeing that those roads will significantly improve wildfire suppression. The agency must explain why this proposal departs from its own prior findings on fire occurrence, and reconcile the rescission with the ignition data in its own DEIS, which reports far higher fire density on roaded land than inside the affected roadless areas. The economics do not hold together either. The agency's own record states 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." This agency is nearly 6.9 billion dollars behind on maintaining roads it already has, against a budget of about 75 million a year. Building new roads into country that has none cannot be justified under those conditions. Explain how expanding a road system carrying a $6.9 billion maintenance backlog serves the public interest. These lands belong to all of us. Hiking, hunting, fishing, backcountry recreation, and the opportunity for solitude are legitimate public-land uses, and the Roadless Rule is what keeps them available. Keep our clean water clean, keep roadless areas roadless, and withdraw this proposal. Sincerely, Concerned Citizen Longmont, Colorado