Comment Analysis · Docket FS-2025-0001

FS-2025-0001-341129

Opposes rescissionA0 noneSubstance 6/24Posted September 9, 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

  • Wildlife Habitat
    • “impact to fish and wildlife habitat and migration corridors”
    • “Native trout in Montana rivers and streams could also be impacted”
    • “Lynx in the Bridger Range would also lose habitat”
    • “Grizzly Bears in the Hyalite-Porcupine-Buffalo Horn and surrounding mountains”
  • Water Quality Quantity
    • “degrading water quality in many headwaters areas”
    • “primary water suppy comes from the Hyalite-Porcuine-Buffalo Horn Wilderness Study Area”
    • “development and resource extraction there could have a large impact on the water quality in the Madison River”
    • “water quality for municipal use and aquatic ecosystem health”
  • Recreation Tourism Public Use
    • “I hike, ski and paddle in the Bridger, Hyalite-Porcupine-Buffalo Horn Wilderness Study Area”
    • “impact on recreation in wild places with limited human impact”
    • “rescission of the roadless rule would directly impact my livelihood”
    • “Losing these wild places will directly impact the outdoor industry”
  • Resource Development Extraction
    • “Mining and oil and gas extraction especially concern me”
    • “potential for pollution and severe degradation of ecosystems is high”
    • “Exchanging temporary profit from resource extraction for the ongoing conservation”
    • “intrusion of industrial activity”

What it names

Roadless areas
College FiordDunoir Special Management UnitGallatin FringeLemhi RangeMadisonMiddle ForkNorth AbsarokaPhillips RidgeTogwotee PassWest Slope TetonsWest Slope WindsWilderness Study Area

The comment

My name is Heather Myers and I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I live in Bozeman, Montana, and I work as an outdoor instructor. I travel in many areas protected by the roadless rule for work and recreation. I hike, ski and paddle in the Bridger, Hyalite-Porcupine-Buffalo Horn Wilderness Study Area, Gallatin Fringe, Madison and North Absaroka roadless areas around Bozeman for fun, and I also teach avalanche courses in these areas. I lead wilderness trips for an outdoor school in the Togwotee Pass, Pacific Creek-Blackrock Peak, Dunoir Special Management Unit, West Slope Winds, Middle Fork, West Slope Tetons, Phillips Ridge and Wilderness Study Area roadless areas in Wyoming, the Palisades and Lemhi Range roadless areas in Idaho, the Dark-Woodenshoe roadless area in Utah and the College Fiord roadless area in Alaska. I am concerned about damage to ecosystems and impact to fish and wildlife habitat and migration corridors in all of these areas, as well as degrading water quality in many headwaters areas that serve mountain towns (like Bozeman, whose primary water suppy comes from the Hyalite-Porcuine-Buffalo Horn Wilderness Study Area). Native trout in Montana rivers and streams could also be impacted by increased sediment due to road construction and logging, such as native Westslope Cutthroat Trout on the Madison River, which are a species of special concern and currently the subject of a Montana Fish, Wildlife and Parks conservation project. The Madison roadless area is a big part of the Madison River watershed, and development and resource extraction there could have a large impact on the water quality in the Madison River. Lynx in the Bridger Range would also lose habitat, as would Grizzly Bears in the Hyalite-Porcupine-Buffalo Horn and surrounding mountains. I am also concerned about the impact on recreation in wild places with limited human impact-- damage to the ecosystems and the intrusion of industrial activity would have an enormous effect on the experience people are able to have in these places. As a hiker, skier and paddler, I am passionate about these forms of recreation, and as an outdoor instructor, rescission of the roadless rule would directly impact my livelihood by degrading the pristine places I lead trips in-- people come on the trips I lead to experience the grandeur and wildness of these places, and roads and industry will severely compromise the experience of backpacking in those places. Not only would I be personally affected, the recreation industry is a large economic sector in the United States, and particularly in the Mountain West. Losing these wild places will directly impact the outdoor industry in many towns in Montana, like Bozeman, Ennis, Livingston, and Big Sky, as well as Lander, Pinedale and Dubois in Wyoming, and many others in Utah, Alaska, Idaho, and elsewhere. Mining and oil and gas extraction especially concern me, as the potential for pollution and severe degradation of ecosystems is high. The release of mining waste into the Animas River in the 2015 Gold King Mine waste water spill had huge and ongoing impacts on fish and aquatic life, water quality in municipal water supplies in downstream communities such as Durango and parts of Navajo Nation, and made the river unsafe for recreation. Exchanging temporary profit from resource extraction for the ongoing conservation and recreation value of these landscapes is short-sighted. I urge you not to partially or fully rescind the roadless rule. The potential damage to ecosystems, natural places for recreation, and water quality for municipal use and aquatic ecosystem health is too great. Thank you for your time and consideration. Sincerely, Heather Myers

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