Comment Analysis · Docket FS-2025-0001

FS-2025-0001-298644

Opposes rescissionA0 noneSubstance 4/24Posted September 1, 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
- “defend the nation's roadless lands”
- “ancient inland rainforests of the Yaak Valley”
- “take millennia to develop to full biodiversity”
- “degrade wildlife habitat”
Water Quality Quantity
- “headwaters of the majority of municipal water supplies in the West”
- “store massive amounts of carbon”
Governance Policy Process
- “vindicative Trump administration”
- “destroying the country's laws and finances”
- “administration is sending out rule-change proposals in waves”
- “lobbyists in D.C. are proposing changes”

What it names

National Forests: Kootenai National Forest

Attachments

1 file. Counts as 1 — Counts as one: The attachments enclose no one else's submissions; the comment counts as one.

Own letter

The comment

A generation ago, in defending the portfolio of roadless lands in the public domain, writers from each of the 50 states published op-eds in local newspapers in each state. Mary Stegner defended the nation’s roadless lands in California, and Bill McKibben, Vermont’s, and so on. The unanimity of the campaign was profound—there may be no more patriotic or common ground issue than Americans’ love for the land where we live—the homeland—and the Clinton administration’s commitment to public engagement on this issue was rewarded with overwhelming number of comments in favor of keeping roadless lands roadless. The fact that the lands that were roadless then still are roadless is testament to two things: the efficacy of the Roadless Rule, and the geographic fact that the vast majority of those lands were roadless because of their inaccessibility. A vindicative Trump administration, willing to subsidize those industries it finds ideologic favor with, is bent on destroying the country’s laws and finances while rewarding his family and lamprey-associates with the spoils of democracy. Nor is his game plan original in the annals of U.S. history. This is an attempt to kill that which his opposition finds sacred—an American civil warfare dating back to the genocide of America’s first people: kill the buffalo to kill Indigenous communities. Trump’s overreach however has given us the opportunity to reiterate our nation’s passionate commitment to defend the land we stand on. Trump was turned back in Texas, when he tried to send bulldozers into Big Bend National Park, and last year when he tried to begin selling off our public lands to private developers. It’s puzzling that these roadless lands in question are managed—theoretically safeguarded—by the Department of Agriculture, a curious assignation, particularly here in the northern Rockies, where forests such as the ancient inland rainforests of the Yaak Valley, on the Kootenai National Forest, can literally take millennia to develop to full biodiversity. Wild forests are but a crop, but a miracle. They store massive amounts of carbon and are of the headwaters of the majority of municipal water supplies in the West. It's the summer of The Odyssey. The challenges befalling our nation seem Odyssean. Public roadless comments are due August 21. In typical fashion, the administration is sending out rule-change proposals in waves, with due dates for comments only days apart. For instance, lobbyists in D.C. are proposing changes to the National Travel Management Plan that will degrade wildlife habitat on lands where roads already exist. There would be an abdication of responsibility for keeping closed roads closed. In essence these two rules pave the way for all national forests to have roads built anywhere, any time, and at any expense. We-the-taxpayers are already reeling from Trump’s military misadventures and $40 trillion deficit. On the Kootenai National Forest, for instance, there are an estimated 10,000 miles of road. Do we really need any more?) In the novel Cold Mountain, the character of Ruby, upon gazing out at a Civil War abomination, says fiercely, “God won’t stand for this war long.” Regardless of one’s religious leanings, it’s a sentiment shared increasingly by a nation under siege, and a democracy in deepest peril. The administration still hasn’t learned what Ed Abbey articulated and what we know as an article of faith: in Montana, we stand for the land we stand on.