Comment Analysis · Docket FS-2025-0001

FS-2025-0001-565513

Opposes rescissionA3 weakSubstance 11/24Owed an answerPosted October 5, 2026 On Regulations.gov

In short: The comment documents specific local impacts in the Flathead Valley, including threats to grizzly bear connectivity, sedimentation in Flathead River headwaters, increased wildfire ignition risks, and economic losses, while citing DEIS data and tribal opposition to support the request to adopt the No Action alternative.

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

A3 weak: Substantive, but easier to set aside.

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.
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.
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.
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
- “adversely affect 327 threatened and endangered species”
- “grizzly bears, Canada lynx, wolverine, and bull trout”
- “keep secure grizzly habitat and that connectivity intact”
Water Quality Quantity
- “road construction and native surface forest roads are the largest source of sediment”
- “headwaters feed the Flathead River and Flathead Lake”
- “Sediment is especially damaging to bull trout spawning streams”
Recreation Tourism Public Use
- “Wild country is a big part of why people live here, visit here, and spend money here”
- “Jewel Basin Hiking Area”
- “projects a $9 million annual loss in visitor spending in local communities”
Economic Impact Fiscal
- “leaves taxpayers with a bill and little to show for it”
- “national deferred maintenance backlog is over $6.9 billion”
- “little commercial timber value”

What it names

National Forests: Flathead National Forest
Roadless areas: Middle Fork

The comment

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

Dear Secretary Rollins, I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I urge the Forest Service to adopt Alternative 1, the No Action alternative, and keep full Roadless Rule protections in place. I live in the Flathead Valley of northwest Montana, and my family owns a outdoor recreation company. Wild country is a big part of why people live here, visit here, and spend money here. About 6.4 million acres of Montana's national forests, roughly 37%, are Inventoried Roadless Areas. Alternative 2 would strip protections from all of it, and Alternative 3 would still open much of it to new roads and logging. Near my home that includes the northern Swan Range and the Jewel Basin Hiking Area, the Whitefish Range west of the North Fork Flathead, the Middle Fork Flathead, the Badger-Two Medicine, and the roadless country bordering the Cabinet Mountains Wilderness on the Kootenai. Wildlife. The DEIS says rescission would "adversely affect" 327 threatened and endangered species and 71 designated critical habitats. In northwest Montana that means grizzly bears, Canada lynx, wolverine, and bull trout, all federally listed and all dependent on large, unfragmented landscapes and cold, clean water. The Swan and Whitefish ranges link Glacier National Park to the Bob Marshall Wilderness complex. How will the agency keep secure grizzly habitat and that connectivity intact once new roads go in? Water. The DEIS states that roadless areas "typically have good water quality due to limited disturbance" and that "road construction and native surface forest roads are the largest source of sediment related to timber harvest operations." These headwaters feed the Flathead River and Flathead Lake, and Wild Montana estimates about a third of Montanans get drinking water from roadless watersheds. Sediment is especially damaging to bull trout spawning streams. How will the agency prevent erosion and sedimentation in these watersheds without the Rule? Fire. The DEIS admits that "road density is linked to human-caused wildfires, and as the density of roads increases so does the probability, number, and frequency of wildfire ignitions." Studies have found fires are four times more likely to start near a road than in a roadless area. Northwest Montana already lives with long smoke seasons. Adding roads to remote country adds ignition points. Cost. The Flathead National Forest already has about 3,500 miles of road and maintains only about half of them. The national deferred maintenance backlog is over $6.9 billion, and the DEIS says new roads could be built across 18.2 million acres in the short term. Much of Montana's roadless land is steep, high-elevation ground with little commercial timber value. Building roads there leaves taxpayers with a bill and little to show for it. The DEIS also projects a $9 million annual loss in visitor spending in local communities, and Montana towns like ours depend on that spending. Process. More than 600,000 people commented last fall, and over 99% opposed rescission. The DEIS notes that "the majority sentiment among Tribal governments consulted is opposition to the proposed rescission," which matters here given the Badger-Two Medicine's importance to the Blackfeet Nation. A decision this large should not be rushed through shortened comment periods. For these reasons, fully or partially rescinding the Roadless Rule under Alternatives 2 and 3 of the draft EIS would be a serious mistake. I oppose the proposal to rescind or alter the Roadless Rule and support Alternative 1, the No Action alternative. Sincerely, C Quinn Kalispell area, Montana