Comment Analysis · Docket FS-2025-0001

FS-2025-0001-540930

Opposes rescissionA2 moderateSubstance 9/24Owed an answerPosted October 4, 2026 On Regulations.gov

In short: The comment documents specific deficiencies in the agency's justification for rescinding the 2001 Roadless Rule, citing data on wildfire ignition density near roads, road maintenance backlogs, and watershed health, while highlighting the lack of public meetings and insufficient comment period duration for a decision affecting 45 million acres, specifically within Montana's national forests.

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

Forest Management Wildfire
- “The Roadless Rule does not stand in the way of fuels reduction”
- “wildfire ignitions are denser near roads”
- “What limits further work is funding, not regulation”
Water Quality Quantity
- “watersheds in roadless areas are far more likely to be in 'properly functioning' condition”
- “protects the drinking water supply of 354 municipal watersheds”
- “34 percent of residents drink water that originates in roadless areas”
Wildlife Habitat
- “provide habitat for hundreds of species listed or proposed for listing”
- “including grizzly bears and lynx”
- “Tribes... rely on intact roadless forests for hunting, fishing, gathering”
Governance Policy Process
- “the Department has held no public meetings on this rescission”
- “99 percent opposed rescission”
- “A decision affecting roughly 45 million acres warrants far more public engagement”

What it names

Roadless areas: Crazy Mountains

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 placeEA analysisAnalytical gapEvidenceRequestAlternativeLegal

Danielle Frevola Missoula, MT October 4, 20206 U.S. Department of Agriculture U.S. Forest Service Re: Opposition to the Proposed Rescission of the 2001 Roadless Area Conservation Rule (Special Areas; Roadless Area Conservation, 91 FR 53827) To Whom It May Concern: I am writing to oppose, in the strongest terms, the proposed rescission of the 2001 Roadless Rule. The Department justifies the proposal by citing wildfire risk, forest health, and the need for local flexibility.[1] The evidence does not support these claims, and I urge you to withdraw the proposal. Wildfire. The Roadless Rule does not stand in the way of fuels reduction; it expressly permits wildfire prevention, suppression, and hazardous fuels treatment [2][3]. Research shows that wildfire ignitions are denser near roads [6]. Further, the Forest Service’s own data estimates that current roadless areas have been treated for wildfire prevention- about 5 percent since 2014 [1]. Additionally, nearly 120 current and former wildland firefighters have written to Congress in support of the rule [9], corroborating further support for current access for wildfire mitigation efforts. What limits further work is funding, not regulation: the Forest Service already carries a road maintenance backlog estimated at between $5 billion and $9 billion [3][4][9]. Local control. The Department says rescinding the rule would restore authority to local forest managers.[1] But managers already have the flexibility the Department describes. The rule expressly allows wildfire prevention and hazardous fuels reduction,[2][3] and where a state wants a roadless policy tailored to local conditions, there is an established path to one, as Idaho and Colorado have shown with their own state-specific roadless rules.[1] A proposal that truly favored local voices would also seek them out. Instead, the Department has held no public meetings on this rescission, even though the original rulemaking drew 1.6 million comments, about 95 percent in support, and more than 600 public meetings.[3] Tribes, many of which rely on intact roadless forests for hunting, fishing, gathering, and cultural practices, are entitled to meaningful consultation as well.[3][9] Local control means little if the communities that live beside these forests are not heard. Economics. Roadless areas already sustain a substantial recreation economy, including more than 25,000 miles of trails, 8,500 climbing routes, 1,000 miles of whitewater, and 10,000 miles of mountain biking trails nationwide.[3] One analysis reported by the Wyoming Wilderness Association puts the annual value of roadless forests near $25 billion, largely from recreation.[9] Timber, by contrast, is a poor financial bet. Studies reported by that group and by Taxpayers for Common Sense indicate the Forest Service often spends more to prepare and administer timber sales than it earns from them.[9] Building roads into remote, marginal areas would add costs the agency is already unable to meet. Water, wildlife, and climate. Forest Service data show that watersheds in roadless areas are far more likely to be in "properly functioning" condition than those outside them.[3] The rule protects the drinking water supply of 354 municipal watersheds, sparing downstream communities the cost of additional filtration.[3] In Montana, about 34 percent of residents drink water that originates in roadless areas.[4] These lands also provide habitat for hundreds of species listed or proposed for listing under the Endangered Species Act, including grizzly bears and lynx, and they store significant amounts of carbon.[3] Public input. More than 600,000 comments were submitted during the initial comment period, and the Forest Service itself acknowledges that 99 percent opposed rescission.[7] By comparison, the original rulemaking allowed 129 days for public comment, and the 2005 rescission attempt allowed 182.[7] This proposal initially allowed about a month and was extended only to October 6.[8] A decision affecting roughly 45 million acres warrants far more public engagement. Notably, among the alternatives in the Draft EIS, only the No Action alternative preserves roadless protections.[9] Montana. In Montana, the rule protects about 6 million acres, roughly a third of our national forest land. That includes the Beartooth Front, the Bridger Range, the eastern Bitterroots, the Crazy Mountains, and the Swan Range.[4] [Optional: add a sentence about a specific roadless area you use and why it matters to you.] If the goal is to reduce wildfire risk, the Department should fund fuels work near communities and in areas that are already roaded, where it can begin immediately without removing protections. I ask that you retain the 2001 Roadless Rule in full. Thank you for considering my comments. Sincerely, Danie Frevola Frevolad1@gmail.Com **See references in the attached letter