Comment Analysis · Docket FS-2025-0001

FS-2025-0001-611020

Opposes rescissionA0 noneSubstance 9/24Posted October 7, 2026 On Regulations.gov

In short: The comment documents specific recreational use of the Wind River Range in Bridger-Teton National Forest and the Roaring Plains in Monongahela National Forest, argues that the agency has not documented the wildfire risks justifying rescission of the Roadless Rule, and requests the selection of the no-action alternative in the draft EIS.

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

Environmental Protection Biodiversity
- “sustain biodiversity”
- “Roads fragment habitat”
- “carry invasive species into new places”
- “ecological value are very hard to bring back”
Recreation Tourism Public Use
- “hike and backpack”
- “offer recreation and solitude”
- “felt like raw wilderness”
- “wild character”
Water Quality Quantity
- “protect clean water”
- “cause erosion”
Forest Management Wildfire
- “main justification for rescission is wildfire risk”
- “permits cutting small-diameter timber to reduce the risk”
- “permits road construction when needed to protect public health and safety”
- “not a proportionate response to a problem the agency has not documented”

What it names

National Forests: Bridger-Teton National Forest Monongahela National Forest

The comment

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

I am writing to oppose any revision to the Roadless Rule that would permit new roads, development, or commercial activity in the protected roadless areas of our national forests. I live in Maryland and travel regularly to national forests in other states to hike and backpack. Roadless areas shelter wildlife, protect clean water, sustain biodiversity, and store carbon. They also offer recreation and solitude that can't be recovered once development moves in. Two places in particular matter to me. I have backpacked on the west side of the Wind River Range in the Bridger-Teton National Forest [number of trips], most recently in [year]. [One specific Wind River detail.] The Bridger-Teton has roughly 1.43 million acres of inventoried roadless area that this rescission would affect. Closer to home, I hiked the Roaring Plains loop in West Virginia's Monongahela National Forest in 2025. It felt like raw wilderness, with abundant wildlife and some of the most diverse plant life I have seen on the East Coast. Together with neighboring Flatrock Plains, the Roaring Plains form the highest plateau in the eastern United States, yet when Congress designated the Roaring Plains West Wilderness in 2009, it protected only part of that high country. Roaring Plains North and Roaring Plains East still depend on the Roadless Rule. The agency's main justification for rescission is wildfire risk, but the 2001 rule already allows for that work. It permits cutting small-diameter timber to reduce the risk of uncharacteristic wildfire, and it permits road construction when needed to protect public health and safety from an imminent threat of fire. If the agency believes these exceptions are inadequate, it should identify the specific fuels reduction projects the rule has prevented. Removing protections from nearly 45 million acres is not a proportionate response to a problem the agency has not documented. The effects of a new road reach well beyond the road itself. Roads fragment habitat, cause erosion, carry invasive species into new places, and bring more people along with more pressure for further development. Once an intact forest has been opened up, its wild character and ecological value are very hard to bring back. National forests belong to all of us and should be managed for the public's long-term benefit. I ask the agency to select the no-action alternative in the draft environmental impact statement, keep the current Roadless Rule in place, and reject any proposal that would weaken protections for roadless lands.