Comment Analysis · Docket FS-2025-0001

FS-2025-0001-479992

Neutral / unclearA2 moderateSubstance 9/24Owed an answerPosted September 24, 2026 On Regulations.gov

In short: The comment establishes that the current 'one size fits all' Roadless Rule is insufficient for the Bitterroot National Forest and requests a site-specific, collaboratively developed alternative that allows individual evaluation of roadless areas for forest health, wildfire risk, and other values before boundary changes or management modifications are made.

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 Alternative.

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

Governance Policy Process
- “collaboratively developed alternative”
- “site-specific process”
- “deliberate public process”
- “public should be collaboratively engaged”
Forest Management Wildfire
- “forest restoration”
- “reduction of fire risk”
- “fuel conditions”
- “wildfire risk”
Environmental Protection Biodiversity
- “wildlife habitat”
- “wildlife connectivity”
- “old growth”
- “watershed protection”

What it names

National Forests: Bitterroot National Forest

Attachments

1 file. Counts as 1 — Counts as one: The attachments enclose no one else's submissions; the comment counts as one.

Own letter

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeAnalytical gapEvidenceRequestAlternative

The following are comments from The Ravalli County Collaborative of Ravalli County, Montana (RCC) on the 2001 Roadless Area Conservation Rule Recission Draft EIS-RIN 0596-AD66. We are a diverse group of dedicated volunteers first appointed in 2018 by the Board of Ravalli County Commissioners to promote the wise use and management of natural resources within Ravalli County. Members of our group are committed to working collaboratively, to achieve balanced decisions that reflect the diverse values of our community. The 2001 Roadless Rule identified approximately 447,000 acres on the Bitterroot National Forest that had not been accessed by constructed roads for timber harvesting up to that point in the history of the Forest. These remaining unroaded areas are highly valued for their wildlife habitat and quiet non-motorized recreational opportunities. But we also recognize that conditions have changed since 2001 and much of the Forest, not just these roadless areas, needs forest restoration and reduction of fire risk to adjacent private property. We believe that none of the alternatives sufficiently address this important and controversial issue. Each inventoried roadless area of the Forest is unique. The current “one size fits all” rule as written may be adequate in one area of the National Forest system and insufficient in another to address management issues that have arisen since the 2001 rule has been applied. There should be a collaboratively developed alternative that outlines a site-specific process that requires each forest to evaluate each area individually. Before boundary changes or more intense management direction is recommended, forest wide values and issues evaluated should include forest health, fuel conditions, wildfire risk, old growth, wildlife connectivity, watershed protection, recreation opportunities, terrain restrictions and access needs. The Chief should direct each Forest Supervisor to identify site specific management direction for each roadless area. The public should be collaboratively engaged to identify where the current direction is adequate, and which ones need the exemptions to be updated and customized to address current management issues. Each Forest Plan should then be amended to formalize direction provided through the Roadless Rule or to modify management direction as appropriate. These areas have such significant value and are so controversial they warrant a deliberate public process to change their future management direction.