Comment Analysis · Docket FS-2025-0001

FS-2025-0001-444322

Opposes rescissionA0 noneSubstance 5/24Posted September 17, 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

Economic Impact Fiscal
- “timber industry is dead in this state”
- “far more local economic activity utilizing these roadless areas”
- “throwing away 100 years of potential revenue”
- “transferring them to out of state corporations”
Forest Management Wildfire
- “increased wildfires our forests in the Northern Rockies now face are the direct result of logging”
- “thinning coniferous forests by removing mature trees as a means of fire prevention actually does the opposite”
- “no need to build new roads to prevent or fight fires”
- “mature forest that is resilient to fire”
Recreation Tourism Public Use
- “fishing, hunting, guiding, backpacking etc.”
- “disrupting the opportunities for outdoor recreational activities”
- “camping, fishing and hunting”
- “recreational user of National Forest lands”
Scientific Research Evidence
- “growing body of evidence that "thinning" coniferous forests... actually does the opposite”
- “average time between harvests is 100+ years”
- “monoculture of Lodgepole Pine at mid-elevations”
- “PhD biologist”

What it names

Roadless areas: Ponderosa Pine

The comment

As a PhD biologist and recreational user of National Forest lands I oppose the rescinding of the Roadless Rule. This proposal is not based on meeting the needs of the regional communities around National Forests, it is a blatant attempt by the timber industry to transfer resources from the American people to private interests for short term gain. The two primary reasons cited for changing the rule are "economic development" and "fire prevention," both are canards. Anyone who lives in Montana can tell you the timber industry is dead in this state, and was dying for decades before the last mills closed - long before the Roadless Rule came into effect. Montana is a terrible place to grow commercial lumber: the average time between harvests is 100+ years, versus around 20 on the Gulf Coastal Plain and 30-40 in coastal Oregon and Washington. Opening Montana's forests to large scale commercial logging will not meaningfully improve the state's economy, there is far more local economic activity utilizing these roadless areas (fishing, hunting, guiding, backpacking etc.) that puts money in local citizens and businesses pockets. Logging and milling operations at their peak employed only a fraction of people now receiving economic benefits from these lands. Reopening our forests to logging won't create jobs, it is going to erase them; taking money and resources out of local pockets and transferring them to out of state corporations. And even that will be a brief hit of revenue before the saleable timber gets logged out and the logging conglomerates pull out again. It is throwing away 100 years of potential revenue from use of the land to get 5-10 years of quick money. As for roads being required for "fire prevention," the increased wildfires our forests in the Northern Rockies now face are the direct result of logging. The timber industry cuts down mature forest that is resilient to fire and leaves early succession regrowth that is far more prone to burning, and when it does burn it burns hotter, faster and is more difficult to control. Logging is a form of disturbance, and in this region most regrowth following such disturbance is Lodgepole Pine (Pinus contorta): a short-lived, weedy species whose life cycle is based on being wiped out by fire every 50 to 100 years. Most of the forest fires we now experience in the Northern Rockies are direct result of logging in the 20th century, which created an expansive monoculture of Lodgepole Pine at mid-elevations that are now reaching the end of their lifecycle and are dying off. These dead and dying Lodgepoles are a low grade timber product, only suitable for fence posts and pulp production. The timber industry is not going to restart logging operations to clear out old Lodgepoles. If they re-enter Montana it will be to go into healthy forest and take mature Ponderosa Pine, Douglas Fir, Western Larch, etc. that have much better fire resistance than the "trash" Lodgepole Pine. These operations will not have any measurable impact on reducing fires, since they aren't going to remove the Lodgepoles and will take the trees most likely to survive fires. There is a growing body of evidence that "thinning" coniferous forests by removing mature trees as a means of fire prevention actually does the opposite, opening the canopy to dry out the understory (making it more vulnerable to fire starts) and keeping a perpetual cohort of juvenile trees that are more likely to burn in a surface fire. The forest fire "problem" in Montana was created by logging, more logging is not going to solve it. There is no need to build new roads to prevent or fight fires. Most of the roadless areas are distant from inhabited districts anyway, with plenty of roaded sections between them that can be used as firebreaks. More economic activity is generated from the forests as they are than by cutting a bunch of roads into them and disrupting the opportunities for outdoor recreational activities like camping, fishing and hunting. Again I affirm: do not repeal the "Roadless Rule."