Comment Analysis · Docket FS-2025-0001

FS-2025-0001-272730

Opposes rescissionA0 noneSubstance 6/24Posted August 26, 2026 On Regulations.gov

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
    • “protection to watersheds, fish and wildlife habitat”
    • “open irreplaceable Montana landscapes up to large-scale logging, road construction, and other development”
    • “industrialize our national forests”
  • Recreation Tourism Public Use
    • “provide recreational opportunities not found in developed areas”
    • “spent many days backpacking and fishing in roadless areas”
    • “wonderful experiences i can not get in developed forests”
  • Water Quality Quantity
    • “protection to watersheds”
    • “irreplaceable roadless values”

What it names

National Forests
Helena National Forest

The comment

Dear Secretary Rollins, I strongly oppose the Proposed Rule rescinding the 2001 Roadless Rule. Roadless portions of the National Forest provide protection to watersheds, fish and wildlife habitat, and provide recreational opportunities not found in developed areas. I spent many days backpacking and fishing in roadless areas of the Custer and Gallation National Forest as a young man and I still fish and hunt in roadless areas of the Helena National Forest. These are wonderful experiences i can not get in developed forests, no matter how much money I spend. Rolling back the Roadless Rule will open irreplaceable Montana landscapes up to large-scale logging, road construction, and other development that will industrialize our national forests. Once these areas are develped they will never be the same again. 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 that needs to be continued. Please adopt the No Action alternative for the Final Rule. Sincerely, Mr. Rudy Verzuh Montana

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