Comment Analysis · Docket FS-2025-0001

FS-2025-0001-572654

Opposes rescissionA2 moderateSubstance 18/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment establishes that the DEIS fails to project sediment delivery to municipal intakes, address tire-derived pollutants, quantify the increase in human-caused ignitions from new road access, or properly assess economic impacts on local small entities, and requests that the agency calculate these specific impacts and weigh reliance interests before finalizing the rescission.

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

Water Quality Quantity
- “protects water that salmon need”
- “Removing riparian vegetation can raise stream temperatures”
- “skid roads... are the main cause of soil erosion”
- “tire-derived pollutants... migrate into waterways”
Wildlife Habitat
- “reduce egg survival, rearing densities and growth of coho salmon”
- “affected area includes Essential Fish Habitat and critical habitats”
- “severe effects on fish and everything that depends on them”
- “salmon runs that are already under pressure”
Forest Management Wildfire
- “Human-caused ignition density is 22.4 fires per million acres... 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”
- “project the expected increase in human-caused ignitions from new access”
Economic Impact Fiscal
- “books lost recreation benefit at a minimum of $6.1 million a year”
- “averaging a $9 million annual expenditure loss across every small firm”
- “assess the impact on the small entities actually operating in the potentially affected roadless areas”
- “withdraw the certification and assess the impact on the small entities”

What it names

Roadless areas: Middle Fork

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 placeLocal knowledgeEA analysisAnalytical gapEvidenceRequest

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Decades spent living next to roadless areas in central Idaho, working as a whitewater guide on the Main Salmon and as a wilderness guard and river ranger on the Middle Fork Salmon, shaped who I am in ways I cannot fully account for. I hunted, fished, camped, hiked, and skied those drainages and carried the same habits into Colorado and Wyoming. Those experiences have been a huge positive influence on my life, and I want the same opportunity to exist for my son and grandchildren. The 2001 Roadless Area Conservation Rule is part of what keeps that opportunity intact. I oppose its rescission. I have commented on this matter before and received no response. I file this comment expecting the agency to engage with the specific points it raises and to answer them in the record it builds. The rule I guided on and worked in protects water that salmon need. Removing riparian vegetation can raise stream temperatures beyond what suits cold-water species, and warmer temperatures can reduce egg survival, rearing densities and growth of coho salmon, and the affected area includes Essential Fish Habitat and critical habitats managed by NMFS. I have watched salmon in those rivers. I have worked that water. I have yet to see a plausible explanation of what we will do once the fisheries have been diminished. Beyond temperature, the DEIS itself acknowledges that skid roads, trails, log landings and similar disturbances within timber sale areas are the main cause of soil erosion and "can contribute up to 90 percent of the sediment generated by timber sale activity," yet no projection of sediment delivery to downstream waters follows that finding. There are more than 7,000 municipal intakes sitting in watersheds that contain affected roadless areas. I ask that the agency calculate the projected sediment load reaching those intakes and place that calculation in the record before any final decision is made. One contamination pathway the DEIS does not appear to address at all is tire-derived pollutants. Compounds including 6PPD and 6PPD-quinone are shed from truck and car tires and migrate into waterways near roads. The resulting water toxicity has severe effects on fish and everything that depends on them. New roads built following rescission would extend the zone of exposure for salmon runs that are already under pressure. I ask the agency to address tire-derived contaminant loading as a distinct water quality effect in any final environmental review. The agency's own fire data undermines a central justification for the proposal. 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 same analysis concedes that road access could increase the number and frequency of wildfires. Despite that, the agency claims the rescission reduces wildfire hazard without quantifying the fires new road access would add. I ask that the agency project the expected increase in human-caused ignitions from new access and weigh it openly against whatever hazard-reduction claim it is advancing. The economic certification is also defective. 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. I was one of those outfitters operating on those rivers. The flexibility analysis reaches its no-impact conclusion by averaging a $9 million annual expenditure loss across every small firm in the sector nationally, rather than examining the guides and outfitters who actually hold permits in the affected areas. That method is not analysis; it is concealment. The agency must withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. Finally, the agency has affirmatively invited public comment but has not committed to weighing what it receives. The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. This comment is such a reliance interest. Decades of work, recreation, and expectation built on the rule's protections are real and they belong on the scale. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one, before it reaches a final conclusion. Sincerely, Steve Moore Captain Cook, HI