Comment Analysis · Docket FS-2025-0001

FS-2025-0001-302833

Opposes rescissionA1 strongSubstance 14/24Owed an answerPosted September 2, 2026 On Regulations.gov

In short: The comment documents that the Draft EIS fails to provide the site-specific NEPA analysis required by 40 CFR 1502 for the Stony Mountain IRA in Bitterroot National Forest, arguing that a programmatic assessment of 2,332 areas is insufficient to capture the distinct ecological and watershed impacts of that specific 44,057-acre area.

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

A1 strong: Must be answered — it names the law.

Owed an answer on Analytical gap, Legal.

Standard dismissals it defeats

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.
Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
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.

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.
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.
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.

Topics

Environmental Protection Biodiversity
- “destroy the ecosystem and fragment one of the few remaining large wilderness areas”
- “intact roadless areas are emerging as some of the most important climate refugia”
- “57% of vulnerable U.S. wildlife species have suitable habitat in roadless areas”
- “unfragmented stopover and breeding habitat that hundreds of species depend on”
Climate Carbon Storage
- “holds carbon and buffers temperature”
- “Tongass roadless areas contain very large biomass and soil carbon stocks”
- “old-growth protection as a critical climate solution”
- “climate refugia on the continent”
Water Quality Quantity
- “unique watershed, habitat, and ecological characteristics”
- “intact hydrology”
- “Section 404 of the Clean Water Act (CWA) establishes a program to regulate the discharge”
- “no discharge of dredged or fill material may be permitted if... the nation's waters would be significantly degraded”
Recreation Tourism Public Use
- “provided a solitude and wildness that deserves to be protected”
- “incredible experience of vast forests and rivers and mountains”
- “people whose lives have been shaped by access to them”
- “undeveloped backcountry forestland”

What it names

National Forests: Bitterroot National Forest
Roadless areas: Stony Mountain
Law cited: 40 CFR 1502

The comment

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

To the Roadless Rule Rulemaking Team: As someone who has made a practice of noticing what's actually present in a place, I'd say that what's present in roadless areas is time — accumulated, undisturbed time — and that's the thing you can't put back. This July we spent 5 days in the Bob Marshall wilderness on a trip that tested me and provided a solitude and wildness that deserves to be protected. It was a truly incredible experience of vast forests and rivers and mountains and wildlife and humans along side it all coexisting. Adding roads to an area like this would destroy the ecosystem and fragment one of the few remaining large wilderness areas we have left. The Department should understand that the Rule's rescission would produce real and lasting consequences — not only for the lands themselves, but for the people whose lives have been shaped by access to them. Regarding the Stony Mountain in the Bitterroot National Forest, Montana: NEPA requires analysis proportional to the significance of the proposed action. The Stony Mountain IRA (44,057 acres) in Bitterroot National Forest has unique watershed, habitat, and ecological characteristics that a programmatic EIS addressing 2,332 areas in aggregate does not and cannot analyze. The DEIS treats 2,332 inventoried roadless areas as interchangeable units for purposes of impact analysis, but the Stony Mountain IRA (44,057 acres) in Bitterroot National Forest has distinct ecological conditions that produce site-specific impacts no programmatic document captures. The DEIS must provide site-specific NEPA analysis for the Stony Mountain IRA (44,057 acres) in Bitterroot National Forest, as required by 40 CFR 1502. A programmatic assessment of 2,332 roadless areas does not satisfy the requirement for analysis proportional to site-specific impacts. "Section 404 of the Clean Water Act (CWA) establishes a program to regulate the discharge of dredged or fill material into waters of the United States, including wetlands. Activities in waters of the United States regulated under this program include fill for development, water resource projects (such as dams and levees), infrastructure development (such as highways and airports) and mining projects. Section 404 requires a permit before dredged or fill material may be discharged into waters of the United States, unless the activity is exempt from Section 404 regulation (e.g., certain farming and forestry activities). The basic premise of the program is that no discharge of dredged or fill material may be permitted if: (1) a practicable alternative exists that is less damaging to the aquatic environment or (2) the nation's waters would be significantly degraded." — U.S. Environmental Protection Agency The proposed rollback of the 2001 Roadless Rule jeopardizes nearly 58 million acres of undeveloped backcountry forestland managed by the U.S. Forest Service, comprising around a third of the territory in our national forest system. These forests have only remained intact because of the Forest Service's nearly 25-year-old commitment not to build roads in these areas for harmful activities like major logging operations or oil-and-gas drilling. As the climate warms and species ranges shift northward and upslope, intact roadless areas are emerging as some of the most important climate refugia on the continent. Their unfragmented condition shelters cool microclimates, intact hydrology, and the connected habitat corridors that wildlife and plant communities need to adapt as conditions change. A growing body of peer-reviewed science identifies inventoried roadless areas as disproportionately important both as ecosystem-scale refugia — high-quality, undisturbed substrate that holds carbon and buffers temperature — and as species-scale refugia for cold-adapted, drought-sensitive, and otherwise climate-vulnerable populations. They also anchor portions of the Pacific, Central, Mississippi, and Atlantic migratory bird flyways, providing the unfragmented stopover and breeding habitat that hundreds of species depend on. Fragmenting these areas with new roads severs the very connectivity that climate adaptation requires. “Species-level modeling shows 57% of vulnerable U.S. wildlife species have suitable habitat in roadless areas. Adding unprotected roadless areas to protected areas markedly reduces poorly-represented species of conservation concern. — Research - Wildlife Habitat” “Tongass roadless areas contain very large biomass and soil carbon stocks, underscoring old-growth protection as a critical climate solution with global significance. — Research - Climate Solutions” Rescission action is opposed; the Department is urged to allow the Rule to stand. With respect, Catherine