Comment Analysis · Docket FS-2025-0001

FS-2025-0001-588144

Opposes rescissionA0 noneSubstance 7/24Posted October 6, 2026 On Regulations.gov

In short: The comment documents specific geographic locations in Idaho (Blaine County, Caribou-Targhee NF, Teton Pass/Palisades) where road construction would exacerbate wildfire and avalanche hazards, degrade water quality and wildlife habitat, and negatively impact the local outdoor recreation economy.

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

Forest Management Wildfire
- “building more backcountry roads is the wrong solution”
- “increase in roads within forest lands is directly correlated to an increase in wildfire activity”
- “Roads bring vehicles, campfires, and people-powered wildfire ignition”
Wildlife Habitat
- “degradation of ... wildlife habitat”
- “intact wildlife habitat that supports robust game populations”
- “direct impacts to fish and wildlife”
Recreation Tourism Public Use
- “outdoor recreation economy in Idaho”
- “unparalleled recreational opportunities”
- “direct negative impact on the quality of the experience in these areas”
Water Quality Quantity
- “degradation of water quality”
- “relies on fresh clean water”
- “direct impacts to fish and wildlife”

What it names

National Forests: Caribou-Targhee National Forest
Roadless areas: Cabin Creek

The comment

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

To whom it may concern, For 25 years, the Roadless Area Conservation Rule has protected some of the most important public lands in the country from new road construction and development. At a time when Western communities are understandably concerned about fire, building more backcountry roads is the wrong solution. Roads bring vehicles, campfires, and people-powered wildfire ignition into places that currently see less traffic. Significant evidence exists that an increase in roads within forest lands is directly correlated to an increase in wildfire activity within those areas (Aplet et al., 2026) A known but often overlooked result of wildfire is a correlated increase in snow avalanche activity (Campbell et al., 2019). Mature forest acts as anchorage for snowpacks on steep hillsides in the western United States. Forests also have a slowing effect on avalanches that start above them and typically reduce the risk to people and structures at lower elevation. When this mature growth is eliminated through wildfire or cutting this anchoring effect is eliminated and new avalanche paths are created. This newly created avalanche terrain increases hazards to recreational users, infrastructure, and in some western communities urban areas. Urban infrastructure commonly exists below designated roadless areas. This increase in hazard may result in the loss of life or property. An example of this increased hazard is Blaine County, Idaho. Wildfire activity in this area has fundamentally altered the avalanche hazard affecting the wildland/urban interface and thus greatly increased avalanche threats to roads, people and property. (Miller et al., 2023). The United States Geological Survey (USGS) recognizes this threat and has gone as far as publishing it on USGS.gov (pubs.usgs.gov/publication/70249585). In addition to increased fire and avalanche hazard, road building and activities in roadless areas would lead to the degradation of water quality and wildlife habitat. This would lead to direct impacts to fish and wildlife, which in turn would affect outdoor recreation opportunities for the people of Idaho and across the US. The outdoor recreation economy in Idaho (where I live) is millions of dollars and relies on fresh clean water and intact wildlife habitat that supports robust game populations. Even though Idaho has its own roadless rule, much of the intact ecosystem starts in Idaho and continues in Wyoming. The national roadless rule provides protection for the whole ecosystem. Specific Example: The West Slope of the Tetons Roadless on the Caribou-Targhee NF offers unparalleled recreational opportunities. In summer and fall there is excellent access for multiple use recreation from hunting and angling, to hiking, horse- back riding, mountain biking and motorized activities. The terrain on the west side of Teton Pass, in the Palisades, including Mail Cabin Creek, Burbank Creek, and Mt. Oliver, offer up world class destinations for backcountry skiing. Terrain further south in the Palisades is accessed for snow-machining. Hundreds of Idahoans (and others from around the world) use this terrain on a daily basis in the winter to enjoy the beauty, solitude, fresh air, and fresh powder provided by these Roadless areas. Road building into these areas would have a direct negative impact on the quality of the experience in these areas. Road building, and the potential logging and associated increase in wildfires has the potential to increase the avalanche activity in these areas. Thick, old growth forest serves to help anchor snow to the slopes and prevent thick wind slabs from forming in many start zones. Rescinding these federal protections undermines decades of durable conservation. The proposal to allow commercial logging and road construction ignoring the existing multi-billion-dollar road maintenance backlog is fiscally irresponsible. The current 2001 framework successfully balances forest health with ecosystem preservation. I urge the Forest Service to keep the national Roadless Rule fully intact. Sincerely, Sarah Carpenter