Comment Analysis · Docket FS-2025-0001

FS-2025-0001-575543

Opposes rescissionA2 moderateSubstance 13/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment documents specific reliance interests in the Potosi area of the Beaverhead-Deerlodge National Forest and identifies deficiencies in the agency's analysis regarding wildfire ignition rates (citing DEIS Table 21), small business impacts (citing a $6.1 million annual loss), and the failure to weigh reliance interests in the Cost Benefit Analysis.

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

  • Recreation Tourism Public Use
    • “thrill of watching a kingfisher dip and dive”
    • “hike and camp frequently in national parks, national forests, BLM lands, and wilderness areas”
    • “precisely because I do not have to deal with cars or other vehicles”
    • “enjoy the peace and fruitfulness of a natural ecosystem”
  • Economic Impact Fiscal
    • “My town's economy depends on outdoor recreation”
    • “threatens both what I go out there for and the economic base of the community”
    • “books lost recreation benefit at a minimum of $6.1 million a year”
    • “concentrated harm to the businesses that actually operate in these specific roadless areas”
  • Forest Management Wildfire
    • “Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires”
    • “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
    • “Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas”
    • “Opening these areas to road construction would bring ignition rates closer to the roaded baseline”
  • Water Quality Quantity
    • “1,287 municipal water intakes across the Northern region”
    • “sit in watersheds containing affected roadless areas”
    • “real reliance on the protections the current rule provides”

What it names

National Forests
Beaverhead-Deerlodge National Forest
Roadless areas
Basin CreekMiddle Mtn. / Tobacco Roots

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeEA analysisAnalytical gapEvidenceRequest

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The thrill of watching a kingfisher dip and dive over the Madison River is not something I take for granted. I hike and camp frequently in national parks, national forests, BLM lands, and wilderness areas across the region, and one of my favorite rides is the Continental Divide Trail portion that runs near my town, precisely because I do not have to deal with cars or other vehicles. My town's economy depends on outdoor recreation, which means the 2001 Roadless Area Conservation Rule is not an abstraction to me. Rescinding it threatens both what I go out there for and the economic base of the community I live in. I oppose the proposed rescission filed under Docket FS-2025-0001 and ask that the agency consider the following. The Potosi area in the Beaverhead-Deerlodge National Forest, one of the inventoried roadless areas directly affected by this proposal, is a place that means a great deal to me and my family. I have spent many days hiking and recreating there. My partner and I first said I love you while camped nearby. The ability to go into the wilderness and enjoy the peace and fruitfulness of a natural ecosystem is one of the pure joys in the world, and that is precisely what the current rule protects. The Highlands, Middle Mtn. / Tobacco Roots, and Basin Creek areas on the same forest matter to me for the same reasons. Montana holds 235 inventoried roadless areas totaling 6,395,392 acres, and the proposal would put all of it at greater risk. The agency's own record undermines the wildfire rationale offered for rescission. 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." If that finding was accurate enough to anchor the original rule, the agency owes a clear explanation of why it no longer controls. I ask that the agency reconcile the proposed rescission with this language, and explain why the policy reversal is warranted in light of these findings. The ignition data reinforces the concern. The DEIS also records that "Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads." Opening these areas to road construction would bring ignition rates closer to the roaded baseline. The agency has not quantified the expected increase in human-caused ignitions that would follow from new road access or weighed that increase against the claimed reduction in wildfire hazard. It must do so before finalizing any rescission. The small-business analysis compounds the problem. The agency's proposal certifies no significant impact on small entities while, as the record itself shows, "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." The guides and outfitters who hold permits to operate in areas like the Beaverhead-Deerlodge are not a national average. Spreading an aggregate loss across every small firm in the sector nationwide obscures the concentrated harm to the businesses that actually operate in these specific roadless areas. The certification should be withdrawn and replaced with an analysis focused on the entities actually holding permits in the potentially affected areas. Finally, The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. This comment is one such interest. My family's attachment to Potosi, my livelihood's connection to outdoor recreation in the Northern Rockies, and the 1,287 municipal water intakes across the Northern region that sit in watersheds containing affected roadless areas all represent real reliance on the protections the current rule provides. An agency reversing course is obligated to identify and weigh the interests its prior policy created. The agency must address the reliance interests submitted through this comment process, including this one, and explain how they were weighed in reaching its final determination. Sincerely, Jordan Straub West Yellowstone Montana

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