Comment Analysis · Docket FS-2025-0001

FS-2025-0001-550100

Opposes rescissionA1 strongSubstance 8/24Owed an answerPosted October 4, 2026 On Regulations.gov

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

A1 strong: Must be answered — it names the law.

Owed an answer on Legal.

Standard dismissals it defeats

  • 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.
  • 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.
  • 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.

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.
  • 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.

Topics

  • Tribal Sovereignty
    • “egregious breach of U.S. Tribal Nations' treaty rights”
    • “circumvents Tribal Historic Preservation protection of sacred sites”
    • “infringement of Treaty & ANILCA Title VIII Rights”
    • “disregard for Tribal rights”
  • Environmental Protection Biodiversity
    • “antithesis of responsible land, water, and wildlife management”
    • “Roadless areas are vital to watersheds, habitat, and wildlife connectivity”
    • “Fish, wildlife, and people all depend on intact forests”
    • “Building roads into intact ecosystems increases the opportunities for fires to start”
  • Economic Impact Fiscal
    • “create undue pressures on both the private sector and taxpayers”
    • “Taxpayers will be stuck with construction costs for roads”
    • “Rescinding the rule will shrink important sources of revenue and funding”
    • “fiscally irresponsible”
  • Legal Regulatory Framework
    • “infringement of... the Endangered Species Act (ESA)”
    • “Federal Land Policy and Management Act (FLPMA)”
    • “National Environmental Policy Act (NEPA)”
    • “Clean Water Act”

What it names

Law cited
Executive Order 13175

The comment

Dear Secretary Rollins, I am writing to express my disapproval of rescinding the 2001 Roadless Rule. This is a betrayal of the American public and the antithesis of responsible land, water, and wildlife management. It is also an egregious breach of U.S. Tribal Nations' treaty rights. Rescinding the rule ignores treaty agreements with Tribal Nations and circumvents Tribal Historic Preservation protection of sacred sites and ancestral remains (under federal law and Executive Order 13175). This is also an infringement of Treaty & ANILCA Title VIII Rights (for Alaska Tribal members), as well as the Endangered Species Act (ESA), the Federal Land Policy and Management Act (FLPMA), the National Environmental Policy Act (NEPA), and the Clean Water Act. It will do immeasurable harm to public landscapes. Roadless areas are vital to watersheds, habitat, and wildlife connectivity. Fish, wildlife, and people all depend on intact forests for many vital reasonswater storage, habitat, clean air, and carbon storage. Wildlands health is important to us all, and for future generations of Montanans. Rescinding the Roadless Rule creates even more threats of wildfire, bringing more traffic into remote placeshuman-caused fires are the most common and often occur within one mile of an existing road. Building roads into intact ecosystems increases the opportunities for fires to start. Rescission of the Roadless Rule would create undue pressures on both the private sector and taxpayers. The outdoor industry relies on roadless areas and intact ecosystems, bringing in revenue to Montana, providing jobs and equipping hunters, anglers, and outdoor enthusiasts. Taxpayers will be stuck with construction costs for roads and an expensive long-term backlog of maintenance. In addition to outdoor jobs, money from responsible recreation also flows to state and federal governments in the form of entrance fees to parks, hunting and fishing licenses, lodging, and campsite fees. Rescinding the rule will shrink important sources of revenue and funding. The Roadless Rule rescission is fiscally irresponsible and illegal. It demonstrates this administrations penchant for deregulation, contempt for public interests, and disregard for Tribal rights. Removing the rule also subverts public wil; the rule is popular with both political parties and has been supported by millions of tax payers/voters. Rescinding this rule is a fast money scheme for a few elitists, not for the benefit of the American public or for our future generations. I urge you to keep the 2001 Roadless Rule. The federal government bears the responsibility to protect the public trust, the law, public lands, and Tribal sovereignty. Rescinding the rule is a land scheme, theft from the American taxpaying voter and an outrageous attack on our waters, lands, and wildlife.

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