Comment Analysis · Docket FS-2025-0001

FS-2025-0001-512028

Opposes rescissionA0 noneSubstance 8/24Posted September 29, 2026 On Regulations.gov

In short: The comment establishes that the commenter, a resident of Missoula, Montana and river guide, has direct personal and professional standing in specific roadless watersheds, and documents that the agency's proposed rescission of the Roadless Rule conflicts with its own Draft EIS findings regarding wildfire risk, water quality, wildlife habitat, and economic impacts in Montana.

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

Wildlife Habitat
- “threaten... big game and fish habitat”
- “93% of elk summer range in Montana is found within roadless areas”
- “79% of roadless areas in Montana are home to native trout”
- “secure habitat during hunting season”
Water Quality Quantity
- “threaten drinking water supplies”
- “water quality degradation from increased sediment and pollutants”
- “altered stream channels, fragmented habitat, and migration barriers”
Recreation Tourism Public Use
- “hunting, angling, paddling, and other outdoor recreation opportunities”
- “Montana's $3.4 billion outdoor recreation industry supports tens of thousands of jobs”
- “intact, roadless landscapes that draw visitors from across the country”
Forest Management Wildfire
- “new roads have been shown to increase human-triggered wildfires”
- “current Roadless Rule already allows exceptions for wildfire treatments”
- “188,393 acres of hazardous fuels treatments conducted in roadless areas”

What it names

Roadless areas: North Fork SmithRock CreekRocky MountainSouth Fork

The comment

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

Dear Secretary Rollins, Thank you for the opportunity to comment on the proposed recission of the 2001 Roadless Area Conservation Rule. I am a resident of Missoula, Montana and a local whitewater paddler and river guide. I have many memories of paddling rivers within and fed by roadless watersheds like the North Fork Blackfoot River, Thompson River, Dearborn River, Big Hole River, and Rock Creek (Montana); Lochsa, lower Selway, St. Joe, South Fork Snake (Idaho); Chetco and North Fork Smith (Oregon). Rolling back the Roadless Rule through either Alternative 2 or 3 will threaten drinking water supplies, big game and fish habitat, and hunting, angling, paddling, and other outdoor recreation opportunities; increase wildfire risk; and burden the Forest Service with more roads it can’t afford to maintain. On one hand, this administration has been clear in that its goal is to increase logging, mining, and energy development across public lands, including within roadless areas. On the other hand, this administration claims that rolling back the Roadless Rule would return decision-making to local officials—”local” officials who remain beholden to the same bosses in DC who are cutting their budgets, firing their staffs, and aggressively mandating expanded logging, mining, and energy development. This administration also falsely claims that repeal is needed for reducing wildfire risk. In fact, new roads have been shown to increase human-triggered wildfires, and the current Roadless Rule already allows exceptions for wildfire treatments. Overall, the agency’s rationale for rolling back the Roadless Rule is unsubstantial, overwhelmingly lacks public support, and conflicts with its own findings in the Draft Environmental Impact Statement. I strongly recommend that the agency adopt Alternative 1, the no-action alternative, which will keep the Roadless Rule in place and retain the benefits it gives me and others including: 93% of elk summer range in Montana is found within roadless areas. Roadless areas also provide secure habitat during hunting season that keeps big game on public land where they are accessible to hunters in top hunting areas like the Elkhorns, Snowcrest, and Rocky Mountain Front. What’s more, 79% of roadless areas in Montana are home to native trout, including bull trout, Westslope cutthroat trout, and Yellowstone cutthroat trout. Studies have demonstrated that roads can lower trout populations by causing water quality degradation from increased sediment and pollutants, as well as altered stream channels, fragmented habitat, and migration barriers. Montana’s $3.4 billion outdoor recreation industry supports tens of thousands of jobs – from outfitters and guides to gear shops, lodging, and local restaurants. This industry thrives because of the intact, roadless landscapes that draw visitors from across the country and provide Montanans with unparalleled access to the outdoors. As of 2023, 78% of human-caused fires on national forests nationwide start within ½ mile of a road. 85% of all wildfires are human-caused. Wildfires are four times more likely to start near roads. The Roadless Rule already allows the Forest Service to treat roadless areas to reduce wildfire risks. Since the 2001 Roadless Rule went into effect, there have been 188,393 acres of hazardous fuels treatments conducted in roadless areas within Montana. This represents 20% of all hazardous fuels treatments during this timeframe. The Roadless Rule Already Allows for: 32% of motorized trails on national forest land in Montana are located within roadless areas, totaling 878 miles of trails open to off-highway vehicles. The Roadless Rule simply prevents new roads 2.2 million acres of roadless areas in Montana are within grazing allotments. This represents approximately 1/3 of all allotments on national forest lands in the state. The 2001 Roadless Rule recognizes valid existing rights for oil and gas development and does not prohibit new leasing. However, over 90% of roadless areas in Montana are rated as having low or very low potential for oil and gas production There are 370,000 miles of road on our national forests, enough to circle the Earth nearly 15 times. The Forest Service is burdened by a $8.6 billion deferred maintenance backlog, 58% of which is due to dilapidated roads. We need to take care of the roads we already have, not add more roads that the Forest Service doesn’t have the resources or personnel to maintain. Thank you again for the opportunity to comment on this important decision that affects me and my livelihood. I strongly recommend that the agency adopt Alternative 1, the no-action alternative, and forego proceeding with rescinding the Roadless Rule.