Comment Analysis · Docket FS-2025-0001

FS-2025-0001-584171

Opposes rescissionA0 noneSubstance 8/24Posted October 6, 2026 On Regulations.gov

In short: The comment documents the specific recreational and ecological reliance on the Dunoir Special Management Unit, Togwotee Pass Roadless Areas, and Spread Creek - Gros Ventre River Roadless Area in Wyoming, asserting that rescinding the Roadless Rule would degrade these specific locations.

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

A0 none: Counted, not answered.

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.
  • Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
  • 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.
  • Outside the scope The agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.
  • 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
    • “threatens to unalterably change and degrade my experience recreating”
    • “access to quiet, primitive, less developed public land”
    • “decrease the quality of recreational opportunities”
    • “offer a caliber of outdoor experience I find lacking”
  • Wildlife Habitat
    • “increase disturbance to wildlife”
    • “leading to habitat avoidance / abandonment”
    • “accelerate noxious weed infestations into undisturbed habitat”
    • “ecologically impoverished places”
  • Forest Management Wildfire
    • “wildfires are more likely to start in the first place in areas where roads exist”
    • “more roads on our forests will improve the situation with wildfires”
    • “providing increased funding for federal employees and/or contractors to carry out prescribed burns”
    • “maintenance backlog and insufficient funds to take care of the roads that already exist”

What it names

National Forests
Shoshone National Forest
Roadless areas
Dunoir Special Management UnitSpread Creek - Gros Ventre RiverTogwotee Pass

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeRequestAlternative

Dear Reviewing Officer, I am writing today in strong opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule. My reasons are, largely twofold: 1) I do not believe all the reasons the Forest Service has put forward for rescinding this rule stand up to scrutiny. One of the chief rationales I hear is that rescission of this rule will help us get a better handle on wildfires. In actuality, the data show that wildfires are more likely to start in the first place in areas where roads exist. I do not think the Forest Service can argue, in good faith, that more roads on our forests will improve the situation with wildfires. I think providing increased funding for federal employees and/or contractors to carry out prescribed burns in the fall and winter would yield much better results. Speaking of funding, for an agency that has a maintenance backlog and insufficient funds to take care of the roads that already exist on our National Forests, I don’t think we should strip away a policy like the Roadless Rule that maintains current road densities on a subset of National Forest lands. 2) Rescission of the Roadless Rule threatens to unalterably change and degrade my experience recreating on cherished Forest Service lands. I live in a rural, remote part of Wyoming specifically to have access to quiet, primitive, less developed public land. The introduction of more roads in these areas would decrease the quality of recreational opportunities on Forest Service land for myself and my family. It's also likely to increase disturbance to wildlife, leading to habitat avoidance / abandonment and accelerate noxious weed infestations into undisturbed habitat they would otherwise struggle to reach. From my home in Dubois, I travel to the Dunoir Special Management Unit and Togwotee Pass Roadless Areas on the Shoshone National Forest and Spread Creek - Gros Ventre River Roadless Area on the Bridger-Teton with my family the whole year through. We hike, camp, hunt, and set camera traps in these places, not just because they are close by, but because they offer a caliber of outdoor experience I find lacking in places with more densely developed road systems. I’ve spent time on forests in Idaho crisscrossed with roads and it would break my heart to see the local Roadless Areas I love turn into similarly overcrowded, overrun, ecologically impoverished places. I fear that is what would happen following rescission of the Roadless Rule. Roadless Areas represent a fraction of the land the Forest Service manages. I ask that you retain the 2001 Roadless Area Rule to better serve the diversity of your public constituency, including those of us that esteem easily accessible quiet recreation, wildlife, and native plant communities. Thank you for the opportunity to comment. Meghan Riley

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