Comment Analysis · Docket FS-2025-0001

FS-2025-0001-390208

Opposes rescissionA3 weakSubstance 11/24Owed an answerPosted September 14, 2026 On Regulations.gov

In short: The comment establishes the commenter's 40-year Forest Service career and specific knowledge of the Beaverhead-Deerlodge National Forest, documents the current staffing deficits in road maintenance crews, and formally defers to the NARFSE letter while opposing the rescission of the Roadless Rule and the loss of 70% of Roadless Areas under Alternative 3.

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

A3 weak: Substantive, but easier to set aside.

Owed an answer on Evidence.

Standard dismissals it defeats

Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
Outside the scope The agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.

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.
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.
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
- “benefits of RAs for wildlife security”
- “big game will be pushed off of the National Forests”
- “Loosing 70% of the RAs as proposed by Alternative 3 is not acceptable”
Water Quality Quantity
- “clean water are well documented”
- “benefits of RAs for... clean water”
Governance Policy Process
- “top-down approach is inevitable”
- “ability of the Forest Service to implement this EIS with the current workforce”
- “recommend to the Roadless Rule not be rescinded”

What it names

National Forests: Beaverhead-Deerlodge National Forest Gallatin National Forest
Roadless areas: Ponderosa Pine

The comment

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

Subject: Roadless Rule Recission Draft EIS Introduction I had almost a 40 career with the Forest Service working on the Nez Perce, Clearwater, Deerlodge, Bighorn, Beaverhead-Deerlodge National Forests and the Pawnee National Grassland. I retired in 2010 but remained on a type 2 fire team until the fall of 2019. The last 20 years of my career were on the Beaverhead-Deerlodge NF. After retirement I continue to use the B-D NF for hunting, fishing. trail hiking and riding. I don't know why the USDA has taken on this additional workload of an EIS when travel plans are not completed for all national forests. Because the Beaverhead-Deerlodge NF does not have a travel plan, resource damage and user conflicts are rampant. I am going to defer my input to the comments provided by the National Association of Retired Forest Service Retirees (NARFSE) letter dated September 3, 2026. The board of NAFSR has recent and extensive experience with managing the Wildland-Urban Interface (WUI) and Roadless Areas (RAs). If the decision maker cannot utilize the recommendations from NAFSR in full then I recommend to the Roadless Rule not be rescinded. Loosing 70% of the RAs as proposed by Alternative 3 is not acceptable. The benefits of RAs for wildlife security and clean water are well documented. I fear that if the miles of open roads are increased on NFs, the big game will be pushed off of the National Forests and on to private land and unavailable for public land hunters to hunt. The Forest Service does not need any more roads. The backlog of unmaintained roads is well documented. This administration has gutted funding for road maintenance. The Beaverhead-Deerlodge has only two people on the road crew when they formerly had 8. The Custer-Gallatin NF doesn't have a road crew. I my area a number of roads are in horrible condition. One of my concerns is the ability of the Forest Service to implement this EIS with the current workforce. It seems like a top-down approach is inevitable, unless not rescinding the Roadless Rule is chosen, When timber harvest is allowed in RAs, I have no problem allowing for harvest of large diameter lodgepole pine. Large diameter Douglas fir and ponderosa pine should be left. Conclusion I cannot overemphasize the need to utilize the comments from the National Association of Retired Forest Service Employees. Thank you for considering my thoughts on this important issue. Introduction