Comment Analysis · Docket FS-2025-0001

FS-2025-0001-572016

Opposes rescissionA2 moderateSubstance 11/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment places on the record specific data from the agency's own DEIS and Cost Benefit Analysis demonstrating that road construction increases wildfire risk and reduces biodiversity, while the economic analysis fails to show a net benefit, thereby challenging the legal and factual basis of the proposed rescission of the Roadless Area Conservation Rule in the Bob Marshall and Gallatin 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.

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
- “More roads equals less habitat and interrupted habitat”
- “grizzly bear, wolverine, elk, and bighorn sheep”
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
- “bird richness declines with road presence”
Forest Management Wildfire
- “The wildfire rationale collapses under the agency's own data”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “road presence is the single strongest predictor of human ignition”
- “far higher fire density on roaded land than inside the affected roadless areas”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “net present value spanning -$92 million to +$199 million”
- “road system being expanded already carries a $6.9 billion maintenance backlog”
- “small-business certification fails on its face”
Recreation Tourism Public Use
- “My work depends on finding beauty uninterrupted by roads, cars, logging trucks”
- “booking recreation losses at a minimum of $6.1 million a year”
- “It is healing and calming to just 'be' in these places”
- “outfitters, guides and tour operators as affected”

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 "Bob," as many of us call it, is a special place, and the word "Wilderness" in its name is not accidental. I hike and camp in western Montana, including the Bob Marshall and also the Gallatin National Forest and the Yellowstone ecosystem. I photograph landscapes, wildflowers, birds, and large mammals. My work depends on finding beauty uninterrupted by roads, cars, logging trucks, structures, or people. More roads equals less habitat and interrupted habitat. It is a fact the agency's own record confirms, and the rescission of the 2001 Roadless Area Conservation Rule cannot be squared with what the agency has already put in writing. The wildfire rationale collapses under 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 agency now proposes to open roadless areas partly on fuels-management grounds while its own draft environmental impact statement records that road presence is the single strongest predictor of human ignition. The 1,483,000 acres of the Bob Marshall Wilderness Complex and the Gallatin's 703,144 acres across 14 inventoried roadless areas sit inside this landscape. Why does the proposal depart from the agency’s own prior findings on fire occurrence, and that it reconcile the rescission with the ignition data in its own DEIS, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic case is just as weak. The agency's own record states: "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." Against that marginal supply figure, the agency's own Cost Benefit Analysis projects only $5.2 to $11.4 million a year in timber revenue to the Forest Service, while booking recreation losses at a minimum of $6.1 million a year and arriving at a net present value spanning -$92 million to +$199 million. The road system being expanded already carries a $6.9 billion maintenance backlog. The Gallatin Range fight has been one of the most contentious roadless battles in the country, pitting backcountry hunters and wildlife advocates against timber interests in grizzly bear habitat, and the verified species of the Custer Gallatin include grizzly bear, wolverine, elk, and bighorn sheep. How does the agency justify expanding that road system when its own analysis cannot establish a net benefit? The wildlife consequences are documented by the agency, not invented by commenters. The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent, 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. The DEIS also quotes the federal grizzly recovery plan: 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. It is healing and calming to just "be" in these places, and there is research that proves this. The fauna and flora of the Bob Marshall and the Gallatin depend on roadless corridors. I want to know whether the agency will address on the record how this proposal avoids those documented harms to species its own biological assessment identifies. The legal history also matters. The record states the USDA "discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The agency tried state-by-state substitution before and lost in the Ninth Circuit. It should explain specifically how this proposal avoids those same deficiencies, rather than simply reasserting that local approaches are preferable. Finally, the small-business certification fails on its face. The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. Montana alone holds 235 inventoried roadless areas totaling 6,395,392 acres. The guides and outfitters holding permits in the affected areas are not the national average firm. The agency should withdraw the certification and assess the actual small entities operating in these places. Rescind the rescission. Sincerely, Rebecca Sobin Missoula, Montana