Comment Analysis · Docket FS-2025-0001

FS-2025-0001-359995

Opposes rescissionA1 strongSubstance 16/24Owed an answerPosted September 12, 2026 On Regulations.gov

In short: The comment documents that the proposed rescission of the 2001 Roadless Rule is unsupported by the agency's own data regarding wildfire risk and economic trade-offs, and requests the adoption of the No Action alternative to preserve the rule nationwide.

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, Evidence, Alternative, 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

  • Recreation Tourism Public Use
    • “lifelong backcountry hiker, hunter, and angler”
    • “recreation economic benefit”
    • “quiet and isolation is incredibly rare”
    • “places to get lost, to find our way, to feel more wild”
  • Forest Management Wildfire
    • “wildfire rationale is not evidence-based”
    • “greater public access can increase human-caused ignition potential”
    • “fuel-reduction treatment within the already-identified 9.8M-acre WUI overlap”
    • “new roads add fire risk”
  • Economic Impact Fiscal
    • “timber revenue gains”
    • “loss in recreation economic benefit”
    • “livelihoods depend on that fishery”
    • “harm recreation-dependent communities”
  • Tribal Sovereignty
    • “Tribal consultation does not support this change”
    • “threatens sovereignty and cultural resources”
    • “majority of Tribes consulted oppose the rule change”

What it names

National Forests
Lolo National Forest
Roadless areas
Rock CreekSilver King
Law cited
36 CFR part 29490 FR 42179

The comment

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

Re: Docket ID FS-2025-0001 / RIN 0596-AD66 - Proposed Rescission of the 2001 Roadless Area Conservation Rule (91 FR 53827, Aug. 20, 2026) To the Forest Service (Attn: Director, Ecosystem Management Coordination): I am writing to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (36 CFR part 294, Subpart B) and to request that USDA select the No Action alternative in the draft Environmental Impact Statement, retaining the rule in its entirety. Who I am: a Montana resident and lifelong backcountry hiker, hunter, and angler. I come from a multi-generation Montana hunting and fishing family; my father is a professional forester, and I grew up recreating in the inventoried roadless areas addressed by this rule. My comment draws on direct, sustained experience with these specific landscapes. What is proposed: USDA proposes to remove and reserve Subpart B in its entirety (91 FR 53831-53832), returning management of all 58.5M acres of inventoried roadless areas to individual national forest land management. The stated rationale (91 FR 53828-53829, "Rationale for the Proposal") is that a single national prohibition limits local flexibility to address wildfire risk, insect and disease outbreaks, and wildland-urban interface (WUI) protection. My experience with these specific lands: Last July, I backpacked for 4 days with my family into the Quigg Peak inventoried roadless area in the Lolo National Forest. We camped in a valley with lush green waist-high vegetation. A creek in the center of the valley tumbled and sang over the rocks. We saw no one around our campsite for miles. As a child, I harvested deer and elk with my father in this same country and the neighboring Silver King and Quigg Peak roadless areas. Coming home to those places, unchanged, is priceless. These areas provide critical summer and winter range for elk, deer, moose, and bighorn sheep, and they feed cold, clean water into Rock Creek, which supports outfitters, trail-ride operators, and fly-fishing guides whose livelihoods depend on that fishery. The wildfire rationale is not evidence-based and does not align with the agency's own analysis. The Summary of Potential Impacts (91 FR 53829) states that only 9.8M acres (24 percent) of potentially affected roadless acreage overlaps with the wildland-urban interface. If community protection from wildfire is the actual goal, that WUI overlap is where resources should be targeted, not a blanket rescission covering the other 76 percent of acres. The document also acknowledges (91 FR 53829) that greater public access can increase human-caused ignition potential, meaning new roads add fire risk. Separately, the same section notes a $6.9B existing deferred maintenance backlog on Forest Service roads and bridges, which undercuts the claim that new road access is a realistic fire-management tool in the near future. The economic case for rescission is marginal and would harm recreation-dependent communities. USDA's own cost-benefit analysis (91 FR 53830, "Summary of Potential Impacts") projects $4.6M to $10.6M yearly in timber revenue gains, against an estimated $6.1M yearly loss in recreation economic benefit. This trade-off is, by the agency's own math, close to a wash and uncertain both ways. In the Rock Creek drainage, recreation losses would land on guides, outfitters, and small businesses that depend on the health and character of these areas. Tribal consultation does not support this change. USDA's summary (91 FR 53831-53832) states that the majority of Tribes consulted oppose the rule change given how it threatens sovereignty and cultural resources, with several requesting a "Strengthened Roadless Rule" or co-management alternative instead. That should weigh heavily. Requested alternative: I ask USDA to adopt the No Action alternative and retain the 2001 Roadless Rule nationwide. If the agency believes flexibility is warranted, I still oppose full rescission but would find a narrower alternative, limited to fuel-reduction treatment within the already-identified 9.8M-acre WUI overlap, without opening remaining acreage to road construction or timber harvest, less objectionable than the current proposal. Broader public support: My position is not a minority view. Comments on the notice of intent (90 FR 42179) ran more than 99% opposed to rescission among over 625,000 individuals and organizations (91 FR 53831). Independent polls found broad, bipartisan public support for keeping the rule intact. This sort of quiet and isolation is incredibly rare, too rare, today, and irreplaceable if lost. To repeal the Roadless Rule is shortsighted. Such a change does not seek to give but to take and take without reciprocity. Not to expand but to contract the gifts nature seeks to give us. We do not need more roads. We need more places to get lost, to find our way, to feel more wild. Sincerely, Anjeli Doty, EdM, Harvard University Missoula/Seattle area, Montana backcountry recreationist

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