Comment Analysis · Docket FS-2025-0001

FS-2025-0001-600866

Opposes rescissionA3 weakSubstance 9/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment establishes that the commenter, a resident of southwest Montana who uses the Custer-Gallatin National Forest, opposes the rescission of the roadless rule, arguing that the agency's DEIS contradicts claims that rescission would reduce wildfire risk or increase timber value, and citing a $10.8 billion deferred maintenance backlog as evidence of the costs associated with existing roads.

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

A3 weak: Substantive, but easier to set aside.

Owed an answer on 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.
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.
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.
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
- “hunt, hike, and camp”
- “outstanding backcountry recreation opportunities”
- “recreational opportunity”
- “keep roadless areas wild”
Environmental Protection Biodiversity
- “conserved some of our nation's most intact fish and wildlife habitat”
- “wildlife habitat”
- “intact fish and wildlife habitat”
Forest Management Wildfire
- “wildfire ignitions increase with greater road access”
- “science-based forest management to address wildfire risk”
- “hazardous fuels reduction”
Water Quality Quantity
- “protects critical water resources”
- “critical water resources”

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 gapEvidenceRequestAlternative

As a resident of southwest Montana I use and benefit from roadless areas regularly and thus I oppose rescinding the roadless area conservation rule. I most regularly visit the roadless areas on the Custer-Gallatin National Forest to hunt, hike, and camp. The allure of these areas also brings a lot of money to our local businesses and economy. The roadless rule has conserved some of our nation's most intact fish and wildlife habitat for 25 years. It protects critical water resources and offers outstanding backcountry recreation opportunities. I feel that Secretary Rollins' statements on how recission would reduce wildfire risk, open vast timber resources, and improve recreation opportunities for the American public are unsupported. The Forest Service's own DEIS does not support these claims, but rather highlights research on how wildfire ignitions increase with greater road access and the timber value is way less than the cost to remove it. We also need to remember why the roadless rule was developed in the first place--there is a $10.8 billion backlog of deferred maintenance on some 370,000 miles of road. I support science-based forest management to address wildfire risk, forest health, and responsible access but rescinding the roadless rule is not the answer. Roadless does not mean unmanaged, and the current rule allows flexibility to address hazardous fuels reduction, grazing, hunting, fishing, and recreation. These multiple uses are important to many Americans! Please keep roadless areas wild so that future generations may experience that wildness and all that it offers as wildlife habitat and recreational opportunity.