Comment Analysis · Docket FS-2025-0001

FS-2025-0001-296257

Opposes rescissionA0 noneSubstance 8/24Posted September 1, 2026 On Regulations.gov

In short: The comment establishes that local landowners adjacent to the Helena and Lewis and Clark National Forests oppose the repeal of the Roadless Area Conservation Rule, citing specific ecological threats to grizzly bear and lynx habitats, the Continental Divide National Scenic Trail, and the Blue Copper Project located 1/4 mile from their property.

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

  • Wildlife Habitat
    • “support wildlife habitat for grizzly bears”
    • “Canada lynx use these forests as a breeding ground”
    • “Roadless areas protect wildlife habitat, biodiversity and migration corridors”
  • Water Quality Quantity
    • “depend on springs to irrigate our pastures”
    • “prevent pollution and soil erosion into waterways”
  • Recreation Tourism Public Use
    • “We hunt in the national forest, recreate there as well”
    • “value of having intact backcountry recreations”
    • “Continental Divide National Scenic Trail goes through these forests”
  • Resource Development Extraction
    • “opening up the USA to developing roads for logging, mining extraction permits”
    • “Blue Copper Project is currently asking for a permit to extract metals”
    • “opening up mine extraction permits, logging and again, mines”

What it names

National Forests
Helena National ForestLewis and Clark National Forest
Roadless areas
Continental Divide National Scenic Trail

The comment

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

We are commenting on the 2001 Roadless Area Conservation Rule reference RIN 0596-AD66. We are adamant that we are not in favor of reversing this ruling and opening up the USA to developing roads for logging, mining extraction permits or mine development. We are local land owners who live adjacent to the Helena National Forest and the Lewis and Clark National Forest. We hunt in the national forest, recreate there as well. We depend on springs to irrigate our pastures that support cattle grazing on our land. There is value of having intact backcountry recreations. The two mentioned forest above support wildlife habitat for grizzly bears who use these forest as a corridor to the Yellowstone area. Canada lynx use these forests as a breeding ground to rebuild their population in Northwest Montana. The Continental Divide National Scenic Trail goes through these forests. Roadless areas protect wildlife habitat, biodiversity and migration corridors, keep invasive species at bay, prevent pollution and soil erosion into waterways. The roadless rule is an ecological boon to the Western United States landscapes where most of the affected areas are located. A 2020 Forest Service study concluded, after nearly 20 years of monitoring data, that more roads do NOT lead to a better forest health through increased fire-management studies. The National Environmental Policy Act requires government to conduct environmental impact assessments on proposed rule changes, a process that can take years. The Trump Administration is fast-tracking that timeline for repealing the roadless ruling and opening up mine extraction permits, logging and again, mines. Blue Copper Project is currently asking for a permit to extract metals from the USFS in our backyard. We are located 1/4 mile from the project's boundary. This is where we live and grow hay for cattle. The backlog of deferred maintenance has grown rapidly according to the draft environmental impact statement the cost of unaddressed maintenance needed just for roads and bridges that can carry passenger vehicles reached US $6.9 billion in 2024. Where is the tax burden going to fall when more roads are built? We must slow down and protect 45 million acres NOW so future generations can enjoy the same freedom to explore wild public lands that we do today. Consider our comments and those of others who are in favor of keeping our Country's roadless areas intact.

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