Comment Analysis · Docket FS-2025-0001

FS-2025-0001-269663

Opposes rescissionA0 noneSubstance 7/24Posted August 25, 2026 On Regulations.gov

In short: The comment establishes that the commenter is a fourth-generation native and ranch owner in the Highwood Mountains of Montana who opposes the rescission of the 2001 Roadless Rule, arguing that it protects irreplaceable landscapes from industrialization and supports local economic and cultural values.

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
    • “open irreplaceable Montana and Western landscapes up to large-scale logging, road construction, and other development”
    • “industrialize our national forests”
    • “protected irreplaceable roadless values”
    • “environmentally sound, multiple-use management tool”
  • Water Quality Quantity
    • “important the forest land is for the snow pack that ensures strong surface and ground water”
    • “most vital wheat producing area in our nation”
    • “entirety of Californias Central Valley agriculture depends on the Sierra snowpack”
  • Recreation Tourism Public Use
    • “critical to the local tourism community, who come to hike and bike the trails”
    • “beloved it is for our avid hunting and fishing communities”
    • “fundamental to the local economy and the local culture”
  • Economic Impact Fiscal
    • “fiscally responsible”
    • “fuel so much of the local economy”
    • “rural communities who depend on those areas for their livelihoods”

What it names

National Forests
Lewis and Clark National Forest

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapEvidenceLegal

Dear Secretary Rollins, I am an owner of a family-owned, continuously operating cattle property in the Highwood Mountains of Montana, dating to my great-grandfather, who acquired it more than 115 years ago. Stephenson Ranch. I have worked my whole career in agriculture and food production, having overseen and worked in a wide variety of Ag and food businesses in Central California, Texas and elsewhere. Our family ranch property borders on the Lewis and Clark National Forest in Montana. I deeply understand the importance of our National Forests, one of our most important and critical natural treasures. An avid user of that forest for my whole life, I see how vital that area is for the local ag and ranch community, providing critical summer grazing land to small family ranches. Ranches that are only viable due to those longstanding relationships with public lands. I see how important the forest land is for the snow pack that ensures strong surface and ground water for central Montana, the most vital wheat producing area in our nation. How critical it is to the local tourism community, who come to hike and bike the trails. How beloved it is for our avid hunting and fishing communities. That forest and all the public forests in Montana are fundamental to the local economy and the local culture. They are highly valued and used by an amazingly wide swath of people and businesses, across the state. Indeed they fuel so much of the local economy. While my current job has me in Texas, Montana is my home and Im a proud 4th generation native. I know in Texas and California, both states with robust Ag businesses, how critical those same public lands are for the very same reasons. The entirety of Californias Central Valley agriculture depends on the Sierra snowpack. The importance of those Sierra forests fuels the rural communities of California, both the mountain communities and the Central Valley communities. I say that as a former senior executive in Californias largest farming company. I strongly oppose the Proposed Rule rescinding the 2001 Roadless Rule. It has always been a rule with wide bipartisan support It is good for not just the preservation of the land, but for the rural communities who depend on those areas for their livelihoods, and who enjoy the benefits provided. Rolling back the Roadless Rule will open irreplaceable Montana and Western landscapes up to large-scale logging, road construction, and other development that will industrialize our national forests. The Roadless Rule has protected irreplaceable roadless values while permitting fire suppression, fuels mitigation work, trail maintenance, and other forest management activities for the past 25 years. It is a fiscally responsible, environmentally sound, multiple-use management tool. Please adopt the No Action alternative for the Final Rule. Sincerely, Elizabeth Stephenson CEO, SYSTM Foods 2707 Valley Spring Road Austin TX 78746 And President, Stephenson Ranch 13293 Upper Highwood Creek Road Highwood MT 59450

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