Comment Analysis · Docket FS-2025-0001

FS-2025-0001-579697

Opposes rescissionA1 strongSubstance 16/24Owed an answerPosted October 6, 2026 On Regulations.gov

Small family — One letter sent by 3 to 9 people, copied or lightly reworded. This comment stands for 4 submissions in its group; the sender added words of their own. See the letter, its submissions and topics.

In short: The comment establishes that the DEIS fails to provide a sufficient analysis of Tribal rights and interests in the Roadless Rule repeal proposal, specifically citing deficiencies in the Tribal Rights and Interests section (pp. 205–210) and the compliance representation in Table 52 (p. 247), and requests that the FEIS supplement this analysis by identifying treaty rights, mapping roadless acreage overlaps, and analyzing the impact on treaty resources for specific tribes.

Scored with own additions — A family member whose own text beyond the shared letter was scored and combined with the letter's score.

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 Analytical gap, Evidence, Alternative, 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
- “violation of the Constitution, Federal law, treaty obligations, Tribal sovereignty”
- “government-to-government consultation with affected Tribes”
- “sacred sites and ancestral homelands”
- “treaty-reserved rights”
Environmental Protection Biodiversity
- “327 ESA-listed species and 71 critical habitats would be negatively impacted”
- “irrevocable devastation it would cause”
- “destroys habitat”
- “sustain ecosystems Tribal Nations have relied on for generations”
Forest Management Wildfire
- “could actually increase fire risk”
- “More roads will result in more human-caused fires in the backcountry”
- “Agencies already have authority to manage fuels and fight fires in roadless areas”
- “Livestock grazing spreads invasive grasses that exacerbate wildfires”
Water Quality Quantity
- “pollutes clean water”
- “drinking-water sources”

What it names

National Forests: Tongass National Forest
Law cited: E.O. 13175

The comment

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

I urge you to rescind the proposal discussed in FS-2025-0001-223869, Special Areas: Roadless Area Conservation, because of the irrevocable devastation it would cause. Once roads are built, there is no way to undo the damage. According to the analysis in the DEIS, elimination of the Roadless Rule across 45 million acres nationwide would result in a loss of up to $9 million a year from lowered visitor spending, especially hurting local communities, 327 ESA-listed species and 71 critical habitats would be negatively impacted, threaten Tribal sacred and archeological sites, exacerbate the Forest Service’s estimated maintenance backlog of over $8.6 billion covering the existing 370,000 miles of roads, and could actually increase fire risk. More roads will result in more human-caused fires in the backcountry. Research shows that more than 60 percent of human-caused fires on national forests in the Lower 48 states are ignited within 1/8-mile of the nearest road, and 95 percent are ignited within 1/2-mile. Agencies already have authority to manage fuels and fight fires in roadless areas, including the construction of roads for emergency situations. There is no reason to repeal the Roadless Rule. To repeal the Roadless Rule without early, meaningful, government-to-government consultation with affected Tribes would be a violation of the Constitution, Federal law, treaty obligations, Tribal sovereignty, and religious rights. Roadless areas sustain ecosystems Tribal Nations have relied on for generations and are critical to food security for many indigenous communities as well as for sustaining cultural practices, including hunting, fishing, and gathering forest plants for food, medicine, and traditional arts. Roadless areas also include sacred sites and ancestral homelands, such as in the Tongass National Forest for the Tlingit, Haida, and Tsimshian peoples. The DEIS does analyze Tribal rights and interests. The defect is in what that analysis contains, and the DEIS says so itself. This comment is directed at the Tribal Rights and Interests section, pp. 205–210, and at the compliance representation Table 52 rests on it (p. 247). I request that the FEIS supplement the Tribal Rights and Interests analysis to do what the DEIS presently does not: for each tribe whose treaty-reserved rights the record identifies — including at minimum the Swinomish Indian Tribal Community, the Confederated Salish and Kootenai Tribes of the Flathead Nation, and the Shoshone-Bannock Tribes — (1) identify the treaty and the rights reserved; (2) map the inventoried roadless acreage lying within the ceded territory, usual-and-accustomed area, or identified subsistence use area to which those rights attach; (3) state, by alternative, the acres of that overlap in which road construction and timber harvest would become permissible; and (4) analyze the effect of that change on the quantity, quality, and ecological integrity of the treaty resources on which, by the DEIS's own statement at p. 210, the usability of the right depends. Where a boundary is confidential under the authorities the DEIS cites at footnote 65, the acreage can be reported in aggregate without disclosing the boundary, and the FEIS should report it that way and say so rather than omit the analysis. Until that analysis exists, the DEIS cannot support a comparison of alternatives for this resource, and the sections Table 52 identifies cannot document compliance with E.O. 13175. Given the widespread multifaceted harms repealing the Roadless Rule would cause it is imperative that it be improved by: Eliminating the logging loopholes. Logging does not improve anything - it only causes degradation. Instead of the 2000 EIS estimated ~ 1,400 acres of logging in roadless areas across the nation annually, on average from 2008-2018, there has been 3,200 acres of inventoried roadless logging annually in Montana alone. The majority of which was from using Roadless Rule loopholes. Eliminating livestock grazing in our inventoried roadless areas. Livestock grazing spreads invasive grasses that exacerbate wildfires, displaces wildlife, destroys habitat, and pollutes clean water. Despite being only four percent of livestock production in this nation, livestock grazing is pervasive on nearly 250 million acres of our public lands. The Forest Service is clandestinely restocking vacant grazing allotments with cattle, including in roadless areas and Wilderness, without public knowledge or participation. Restricting motorized and mechanized use in our inventoried roadless areas. Research shows that motorized and mechanized access (on roads, trails, or over the snow) harm wildlife, from elk to grizzly bears. Extend the provisions of this strengthened national rule to Idaho and Colorado, which currently have less protective rules. Thank you