Comment Analysis · Docket FS-2025-0001

FS-2025-0001-574716

Opposes rescissionA1 strongSubstance 13/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment establishes that the proposed rescission of the 2001 Roadless Area Conservation Rule fails to analyze reliance interests, reasonable alternatives, and cumulative impacts under NEPA and the APA, while threatening specific water, wildlife, and economic resources in Park County, Montana, and requests the adoption of Alternative 1 (No Action).

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

Environmental Protection Biodiversity
- “Fragmenting irreplaceable wildlife corridors”
- “disrupting Greater Yellowstone Ecosystem connectivity”
- “increasing mortality risks for species listed under ESA Section 7”
- “safeguards the ecological integrity”
Water Quality Quantity
- “Threatening the primary hydrological engine”
- “clean drinking water infrastructure”
- “depend on municipal and agricultural headwaters”
- “violating binding soil disturbance limits”
Legal Regulatory Framework
- “Failure to analyze reliance interests under the APA”
- “illegal NEPA segmentation”
- “statutory cumulative environmental impacts under NEPA”
- “judicial review under NEPA, ESA, the Administrative Procedure Act (APA)”
Recreation Tourism Public Use
- “access backcountry recreation”
- “regularly hike, hunt, and forage”
- “natural amenity economy”
- “secured aesthetic, recreational, economic, and procedural interests”

What it names

National Forests: Gallatin National Forest
Roadless areas: Crazy MountainsWilderness Study Area
Law cited: Executive Order 14072

Attachments

19 files. Counts as 2 — Counted from the files: The enclosed submissions were counted from the files themselves.

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Enclosed submissions
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The comment

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

Park County Environmental Council (PCEC) submits these comments on behalf of our 500 active members and 2,600 regional supporters who live, work, and recreate in Park County, Montana. Since 1990, our mission has focused on protecting the wildlife, critical habitat, public lands, water resources, and community resilience that define the Upper Yellowstone and Shields River watersheds and the communities within them. PCEC members directly rely on and use specific Inventoried Roadless Areas (IRAs) across the Custer Gallatin National Forest. Our members regularly hike, hunt, and forage in the Crazy Mountains IRAs, depend on municipal and agricultural headwaters originating in the Absaroka Range IRAs and access backcountry recreation and outfit in the Hyalite-Porcupine-Buffalo Horn Wilderness Study Area and Gallatin Range IRAs. Any degradation of these specific roadless units directly impairs the indigenous sacred character, secured aesthetic, recreational, economic, and procedural interests of PCEC and its individual members. Park County Environmental Council stands in firm opposition to the U.S. Department of Agriculture (USDA) and U.S. Forest Service’s (USFS) proposed rule change to rescind the 2001 Roadless Area Conservation Rule and strongly advocates for the decision of Alt. 1 – No Action. PCEC specifically requests that the USDA and USFS address the following core legal, procedural, and environmental objections: Objection 1: Failure to analyze reliance interests under the APA by arbitrarily revoking two decades of established landscape protections without considering how local communities and wildlife depend on them, directly threatening Park County’s local culture, traditional ways of life, quality of life, and natural amenity economy. Objection 2: Compromising federal trust obligations, sacred site integrity, and treaty-reserved tribal resources. Objection 3: Degrading high-value natural assets driving the local amenity economy while imposing severe, unanalyzed road maintenance fiscal liabilities on taxpayers. Objection 4: Relying on an incorrect argument that rescission mitigates wildfire risk while failing to analyze reasonable alternatives under NEPA. Objection 5: Threatening the primary hydrological engine and clean drinking water infrastructure of the regional water supply and violating binding soil disturbance limits. Objection 6: Causing direct negative economic and operational impacts on local agricultural producers and forest permittees. Objection 7: Fragmenting irreplaceable wildlife corridors, disrupting Greater Yellowstone Ecosystem connectivity, and increasing mortality risks for species listed under ESA Section 7. Objection 8: Failure to analyze illegal NEPA segmentation, statutory cumulative environmental impacts under NEPA, and carbon emissions under Executive Order 14072. As established, the 2001 Roadless Area Conservation Rule preserves 851,000 acres of IRAs across the Custer Gallatin National Forest alone. Situated in the northern Greater Yellowstone Ecosystem (GYE), Park County serves as the primary year-round gateway to Yellowstone National Park. The 2001 Rule represents one of the most effective, successful, and scientifically supported conservation framework policies in modern public land management. By maintaining strict protections across IRAs, USFS safeguards the ecological integrity, headwater hydrology, cultural heritage, and amenity-driven economic foundations that sustain Park County, the Upper Yellowstone and Shields River watersheds, and the broader GYE. Rescinding the Roadless Rule and replacing national safeguards with localized, fragmented management regimes would initiate irreversible landscape fragmentation across the Custer Gallatin National Forest and beyond. PCEC submits these comments to preserve all factual, ecological, and legal challenges for administrative appeal and judicial review under NEPA, ESA, the Administrative Procedure Act (APA), the National Forest Management Act (NFMA), and the National Historic Preservation Act (NHPA). OBJECTION 1: We object to the removal of over two decades of successful landscape protection and conservation precedent and the failure to analyze reliance interests under the APA. We object because these changes directly threaten Park County’s local culture, traditional ways of life, quality of life, and natural amenity economy. This decision fails to look at how our local communities and wildlife are intertwined with and rely on these protections across the Custer Gallatin National Forest. USFS needs to directly address why its prior factual findings regarding the environmental, ecological, and watershed benefits of roadless protections are no longer valid. A full letter with explanations and references for each objection is attached. Missings files can not be uploaded due to the file limit on this platform. Please contact for any reference requests.