Comment Analysis · Docket FS-2025-0001

FS-2025-0001-523815

Opposes rescissionA2 moderateSubstance 13/24Owed an answerPosted September 30, 2026 On Regulations.gov

In short: The comment documents that the agency's DEIS and Cost Benefit Analysis contain internal contradictions regarding wildfire risk, wildlife mortality, and economic net benefits that the commenter requests be reconciled in the administrative record, specifically citing DEIS Table 21 and specific statistical findings on bird abundance and fire likelihood.

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.

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

Wildlife Habitat
- “bald eagles and Sandhill Cranes”
- “grizzly bear is the other species I think about”
- “bird richness declines with road presence”
- “Verified species of the Custer Gallatin include grizzly bear, wolverine, elk, and bighorn sheep”
Forest Management Wildfire
- “wildfire rationale offered for rescission is contradicted”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “proposal leans on fuels management to justify opening these areas to roads”
- “explain in the record why rescission advances fire safety rather than undermining it”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent”
- “Cost Benefit Analysis that cannot establish a net benefit”
- “recreation losses of at least $6.1 million a year”
- “road system this proposal would expand already carries a $6.9 billion maintenance backlog”
Recreation Tourism Public Use
- “genuine draw for people who travel to watch wildlife”
- “Wildlife watching and photography support real businesses”
- “outfitters, guides and tour operators as affected”
- “lost recreation benefit at a floor of $6.1 million a year”

What it names

National Forests: Gallatin National Forest

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The bald eagles and Sandhill Cranes stopped me cold the first time I saw them, and that kind of encounter has made the greater Gallatin Valley a genuine draw for people who travel to watch wildlife. What is at stake in Docket FS-2025-0001 is the legal foundation that makes those encounters possible: the 2001 Roadless Area Conservation Rule. I oppose its rescission, and I want the agency to answer for what its own record says. The Gallatin Range is one of the most contested roadless landscapes in the country, and the Custer Gallatin National Forest holds what the roadless inventory confirms are 14 inventoried roadless areas totaling 703,144 acres on the Gallatin side and 16 more totaling 144,945 acres on the Custer side, forming the northeastern wall of the Greater Yellowstone Ecosystem. I have watched bird species across that valley and beyond, and I have begun photographing wildlife in these wild spaces because they still function as wild spaces. The rule is the reason they do. Roads are the mechanism of harm, and the agency knows it. I watch for birds across this landscape, and the DEIS cites the findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. The grizzly bear is the other species I think about when I photograph here. Montana and Wyoming cannot support grizzlies and wolves without the protection the roadless rule provides, and the agency's own record agrees with that instinct: the DEIS quotes the federal grizzly recovery plan to the effect that the increased contact and conflict that come with open roads in grizzly habitat can ultimately end in grizzly mortality, and shooting, habituation and food reward all increase with the use of even secondary unpaved roads. Verified species of the Custer Gallatin include grizzly bear, wolverine, elk, and bighorn sheep. The proposal threatens all of them. I ask the agency to explain, in writing in this docket, how it reconciles rescission with those two passages from its own environmental review. The wildfire rationale offered for rescission is contradicted by the agency's own data. The DEIS states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal leans on fuels management to justify opening these areas to roads, yet the draft environmental impact statement places human ignition risk squarely on the roaded side of the ledger. The agency must reconcile that finding with DEIS Table 21 and explain in the record why rescission advances fire safety rather than undermining it. The economic case falls apart on inspection. The agency's own record concedes 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." Alongside that admission sits a Cost Benefit Analysis that cannot establish a net benefit, projecting timber revenue of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year and a net present value range spanning negative $92 million to positive $199 million, all while the road system this proposal would expand already carries a $6.9 billion maintenance backlog. How does the agency justify that expansion on these numbers? That question requires a direct answer. Finally, the regulatory flexibility certification claiming no significant impact on small entities is inconsistent with the analysis beside it. The DEIS names outfitters, guides and tour operators as affected, and the Cost Benefit Analysis books lost recreation benefit at a floor of $6.1 million a year. The certification reaches its conclusion by averaging losses across every small firm in the sector nationally rather than examining the outfitters and guides actually holding permits in the affected areas. Wildlife watching and photography support real businesses in the Gallatin Valley. The agency should withdraw the certification and conduct an honest assessment of the small entities actually operating in these landscapes. Sincerely, Rachael Meadows Bozeman, MT