Comment Analysis · Docket FS-2025-0001

FS-2025-0001-589841

Opposes rescissionA0 noneSubstance 7/24Posted October 6, 2026 On Regulations.gov

In short: The comment documents specific local impacts in Montana (Swan Mountains, Bitterroot Range, etc.) and cites USDA FS-905 statistics to argue that the agency's analysis fails to account for the $10.8 trillion deferred maintenance backlog and the lack of local logging infrastructure, thereby supporting the request to retain the Roadless Area Rule.

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

A0 none: Counted, not answered.

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.
Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
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.
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.

Topics

Water Quality Quantity
- “roads bring water pollution which harms trout”
- “preserves watersheds”
- “watershed degradation”
Recreation Tourism Public Use
- “thriving recreation industry”
- “unapparelled recreation opportunities”
- “harm the local tourism economy”
- “reduce recreation opportunities for locals”
Economic Impact Fiscal
- “bad fiscal management”
- “no local economic benefit”
- “economic benefits from logging... would go to out of state companies”
- “Local businesses... benefit from these areas”
Environmental Protection Biodiversity
- “complex, beautiful ecosystems that would be decimated”
- “invasive plants and other non-native species”
- “conserves priceless ecosystems”

What it names

Works cited: Healey 2020

The comment

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

I am writing to oppose any changes to the current Roadless Area Rule. I am a long-time resident of Montana, and have many family members who live in Northern Michigan, both areas that are home to and benefit from many inventoried roadless areas on US Forest Service and other Federal Public Lands. Removal or reductions of roadless rule protections would cause a noticeable detriment to my quality of life, safety, and wellbeing. As a resident of Northwest Montana, I have personally recreated in a number of inventoried roadless areas, including (but not limited to) in the Swan Mountains, Bitterroot Range, Cabinet Mountains, Beaverhead Mountains, and the area surrounding the Bob Marshall Wilderness complex. These areas feature complex, beautiful ecosystems that would be decimated by the introduction of roads. Studies show that roads bring water pollution which harms trout and other critical species (Sources: Bull Trout Distribution. 2019. Pacific States Marine Fisheries Commission, Portland, OR.; May, B. E., B. J. Writer and S. Albeke. 2012. Redband Status Update Summary. Prepared by Wild Trout Enterprises, LLC, Bozeman, MT.; Greenback Cutthroat Trout Conservation Populations. 2020. Colorado Parks & Wildlife, Denver, CO.) invasive plants and other non-native species (Source: Healey, Sean P. 2020 Long-term forest health implications of roadlessness. Environmental Research Letters. 15: 104023.) and increased risk for wildfire (source: Roadless: Active Management and Fire, A GIS data analysis and research review. Trout Unlimited, September 2, 2026: https://storymaps.arcgis.com/stories/3aecb3a57df8494d8c74582686feaefa). All of these impacts threaten my way of life and the wellbeing of my community and neighbors. I have also worked and recreated in areas of Montana that lack roadless protections. There are many of them: we do not need more. In fact, most of the roads that are built into our Forests and other public lands are currently in shambles: rutted out, eroding, and unsafe for most vehicles to actually use, so unless someone has an ATV or a dirt bike, these roads don’t actually provide increased access or safety. Due to our geography and weather, any new roads built after a recission of the roadless rule would quickly deteriorate to this same state, essentially causing scars across the landscape that don’t actually provide increased access for the majority of Americans. There is already a major deferred maintenance backlog across the National Forest System and other public lands: the US Department of Agriculture estimated recently that there is a $10.8. trillion deferred maintenance backlog, of which 55 percent is due to dilapidated roads that already exist. How does the Federal Government expect to keep up with this existing backlog, let alone deal with miles of new roads built into areas that do not currently have them. Federal Land management agencies are already facing significant reductions in funding; asking them to take on even more maintenance is just bad fiscal management. And asking them to not maintain the new roads would be unsafe, unwise, and could ultimately lead to the sell off or loss of public lands, all unacceptable outcomes. (U.S. Department of Agriculture Forest Service. 2025. FS-905 National Forest System Statistics Fiscal Year 2024. https://www.fs.usda.gov/sites/default/files/fs_media/fs_document/FY24-forest-system-stats.pdf ) I am also concerned about the myth that removing roadless protections will somehow magically bring back the US logging industry. This is false. To have an active logging industry, you need infrastructure. If you visit my area of Montana, you will see that mills no longer exist. They aren’t just closed—they have been demolished, such as the former Pyramid Lumber mill in Seeley Lake, Montana. The railroads, too, have been decommissioned. In the meantime, a thriving recreation industry has risen up, buoyed by the thriving, roadless forests which offer unapparelled recreation opportunities, thriving fish and wildlife populations. Local businesses, including lodging, restaurants, and guide services, benefit from these areas and help the local economy. If the Forest Service decides to open up the roadless areas in the Swan Range to roads and development, there would be no local economic benefit because the mill no longer exists. Any economic benefits from logging in these areas (if any) would go to out of state companies, not locals. Developing these areas would harm the local tourism economy, decimate the surrounding ecosystem, reduce recreation opportunities for locals and destroy our forests through invasive species, watershed degradation, and increased wildfire risk. Please reverse this unwise decision, and keep the roadless rule. It is of great benefit to local communities, conserves priceless ecosystems, preserves watersheds, and helps protect our communities from wildfire, invasive species.