Comment Analysis · Docket FS-2025-0001

FS-2025-0001-463416

Opposes rescissionA2 moderateSubstance 15/24Owed an answerPosted September 22, 2026 On Regulations.gov

In short: The comment establishes that the agency's proposal to rescind the Roadless Area Conservation Rule fails to adequately weigh reliance interests, reconcile its own Cost Benefit Analysis showing no clear net economic benefit, address the specific impacts on small businesses in Montana, or quantify the increased wildfire risk from new road access as documented in the DEIS.

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

A2 moderate: Hard to dismiss — it shows cause and effect.

Owed an answer on Analytical gap, 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.
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.

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.
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

Recreation Tourism Public Use
- “taught my daughter to fish, mountain bike, and backpack”
- “recreation losses of at least $6.1 million a year”
- “outfitters, guides and tour operators as affected”
- “quiet, remote, and backcountry recreation values”
Economic Impact Fiscal
- “net present value spanning -$92 million to +$199 million”
- “road maintenance backlog already sitting at $6.9 billion”
- “small-business certification deserves the same scrutiny”
- “total timber volume affected by this rule is less than 0.5 percent”
Forest Management Wildfire
- “Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land”
- “new road access could increase the number and frequency of wildfires”
- “weeks if not months of unhealthy air every summer”
- “quantify the expected increase in human-caused ignitions from new road access”
Governance Policy Process
- “government doesn't appear to care what a resounding majority of Americans want”
- “agency solicited reliance interests and then did nothing visible with them”
- “identify and weigh the reliance interests described in the comments”
- “The agency's own framing invites this”

What it names

National Forests: Lolo National Forest
Roadless areas: Lolo CreekStark Mountain

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeEA analysisAnalytical gapEvidenceRequest

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Rattlesnake Wilderness is where I taught my daughter to fish, mountain bike, and backpack. We go there to take in the seasons, watch the wildlife, and breathe the fresh mountain air. That wilderness sits inside the Lolo National Forest, alongside roadless areas like Stark Mountain and Lolo Creek, and it is the kind of landscape this rule has protected for over two decades. I am submitting this comment in opposition to Docket FS-2025-0001. I submitted a comment during the 2025 attempt to rescind the rule. I was not shocked to receive no response from the Department, but it still frustrates me that the government doesn't appear to care what a resounding majority of Americans want. The agency solicited reliance interests and then did nothing visible with them. The agency's own framing invites this: "The proposal solicits 'any reliance interests in the current rule that could be affected by this proposal' (91 FR 53830-31), and the Cost Benefit Analysis weighs none." This comment is one such interest. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one, before any final action is taken. On the economics: the record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency is proposing to dismantle a rule that protects millions of acres on the basis of contributions this modest. More striking, the agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year, with a net present value spanning -$92 million to +$199 million. That range does not establish a net benefit, and it does not account for a road maintenance backlog already sitting at $6.9 billion. I ask that the agency reconcile the proposal with that analysis and explain how an action that cannot demonstrate net economic benefit justifies expanding the very road system that backlog represents. The small-business certification deserves the same scrutiny. "The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year." The supporting analysis reaches its no-impact conclusion by spreading losses across the national average firm rather than examining the outfitters and guides who actually hold permits in the affected roadless areas, and it concedes that some of those firms may lose those receipts. Montana alone holds 235 inventoried roadless areas totaling 6,395,392 acres, and the Northern region contains 1,287 municipal water intakes in watersheds with affected roadless areas. The small businesses and communities downstream from places like Lolo Creek and Stark Mountain are not national averages. The agency should withdraw the certification and assess the impact on the specific small entities operating in and around these areas. When I was a kid, fire season was not part of everyday vernacular. Now it is guaranteed every summer. Out here in Montana, we are subjected to weeks if not months of unhealthy air every summer, and it is getting worse. The agency's own data make the connection to roads plain: "Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads." The effects analysis concedes that new road access could increase the number and frequency of wildfires, yet the proposal is advanced in part on wildfire-reduction grounds. How does the agency square those two positions? I expect a direct answer: the agency must quantify the expected increase in human-caused ignitions from new road access and weigh that figure against the claimed reduction in wildfire hazard before this proposal advances any further. Thank you for your time, Kerry Gallagher Missoula, Montana