Comment Analysis · Docket FS-2025-0001

FS-2025-0001-359127

Supports rescissionA0 noneSubstance 5/24Posted September 12, 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

  • Forest Management Wildfire
    • “active management is essential to maintaining resilient ecosystems”
    • “reduce wildfire risk”
    • “fuel reduction, and restoration treatments”
    • “unmanaged fuel loads, dead timber, and catastrophic wildfires”
  • Wildlife Habitat
    • “monitor and manage wildlife populations effectively”
    • “habitat improvement projects”
    • “sustain wildlife populations”
    • “endangered species recovery efforts”
  • Governance Policy Process
    • “Reverce the roadless act”
    • “soften wilderness hard lines”
    • “thoughtful balance between preservation and active stewardship”
    • “local experience”

What it names

National Forests
Beaverhead-Deerlodge National Forest

The comment

Having spent many years studying the Roadless Rule as an outfitter in the Absaroka-Beartooth and Lee Metcalf wilderness areas, as a hunter-conservationist, and as a Montana private landowner bordering Beaverhead-Deerlodge national forest which is presently heavily beetle-killed and largely untreated forests. I have observed few benefits and more unintended consequences of strict roadless and wilderness designations. While wilderness and roadless areas provide important habitat protection and preserve natural landscapes, they can also create significant challenges for effective wildlife and forest management. In many cases, state and federal wildlife managers face restrictions that make it difficult, and sometimes impossible, to monitor and manage wildlife populations effectively. For example, the use of helicopters for capturing and collaring animals for research, population monitoring, and endangered species recovery efforts can be limited by access restrictions. These constraints can also hinder habitat improvement projects, water developments for wildlife and fisheries, disease monitoring, invasive species control, and timely responses to changing environmental conditions. From a forest health perspective, active management is essential to maintaining resilient ecosystems. Douglas-fir and Montana's native pine species are among the largest and fastest-growing living organisms on the landscape. When unmanaged they become evasive, these forests can provide sustainable habitat that supports a wide diversity of flora and fauna while also contributing to water quality, carbon storage, and economic vitality. Active forest management, including thinning, fuel reduction, and restoration treatments, can create healthier and more resilient forests that are better able to withstand insects, disease, drought, and catastrophic wildfire. One of the challenges in public land policy is that forest ecosystems operate on long timelines, like centuries to develop fauna and flora diverity. Decisions made today to produce measurable positive results will take only decades not centuries to show positive results. Delaying management actions until problems become severe frequently results in fewer options and greater ecological and economic costs. Responsible intervention, guided by sound science and local experience, can help ensure that our forests remain productive, diverse, and sustainable for future generations. As someone whose property borders these forests, I have firsthand concerns about the impacts that unmanaged fuel loads, dead timber, and catastrophic wildfires can have on wildlife habitat, neighboring private lands, watersheds, and rural communities. I strongly support conservation and the preservation of wild landscapes. However, conservation should also include practical, science-based management tools that allow wildlife professionals and land managers to actively maintain healthy forests, sustain wildlife populations, reduce wildfire risk, and respond to ecological challenges as conditions change. True conservation is not simply locking landscapes away from human influence. It is ensuring that future generations inherit healthy forests, abundant wildlife, clean water, and resilient ecosystems. Achieving that goal requires a thoughtful balance between preservation and active stewardship, recognizing that well-managed forests can deliver ecological benefits within decades rather than leaving future generations to address problems that have been allowed to grow for the past 50 years. No new wilderness is needed and soften wilderness hard lines. Reverce the roadless act. Thank you for the opportunity to comment. Jack Atcheson Whitehall, MT

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