Comment Analysis · Docket FS-2025-0001

FS-2025-0001-601935

Opposes rescissionA0 noneSubstance 5/24Posted October 7, 2026 On Regulations.gov

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

Environmental Protection Biodiversity
- “human impacts on Earth are reducing biodiversity”
- “integrity and continuity of the various regional ecosystems”
- “protect the roadless areas we have already set aside”
- “We need biodiversity for our own survival”
Wildlife Habitat
- “protection of fish, bears, wolves, and many other species”
- “hunt deer, elk, antelope, grouse, and pheasant”
- “many animals depend on”
- “regional ecosystems that many animals depend on”
Recreation Tourism Public Use
- “hiked many times in the Jewel Basin hiking area”
- “scatter my ashes there”
- “quiet, remote, and backcountry recreation values”
- “fragile and important roadless areas”

What it names

Works cited: Johnston et al. 2023

Attachments

1 file. Counts as 1 — Counts as one: The attachments enclose no one else's submissions; the comment counts as one.

Own letter

The comment

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. My name is Cody Benkelman, and I live in Whitefish Montana where all three of my kids were born. I was born in Polson Montana, and have been a lifelong hunter and fisherman. I’ve been fortunate to hunt deer, elk, antelope, grouse, and pheasant, and fish the lakes and streams of western Montana. I’ve also traveled to Europe, Australia, and southeast Asia, and I’m a firm believer that our human impacts on Earth are reducing biodiversity and putting our future at risk. Many people that consider themselves environmentalists will argue for the protection of fish, bears, wolves, and many other species – and I typically agree with most of those policies – but too often I think we fail to acknowledge that the security of humanity itself is also at risk. We need biodiversity for our own survival. I know many people in this region depend on a stable forest products industry for their livelihoods, and I respect that. I don’t propose to shut down all logging and all development, but I have to believe we’ve already exploited enough of the planet. I feel we need to focus on proving that we can maintain our economy and ensure a stable future with proper stewardship of the vast areas of land that are already developed – the fraction of the Earth that has not yet been developed (or that is recovering from past development) is already small. I know that the existing roadless rule does still allow future development in roadless areas, but requires thoughtful review before proceeding. Let’s honor those existing rules and work together to manage the lands we are already using for human development, and continue to protect the roadless areas we have already set aside. This is especially important for the integrity and continuity of the various regional ecosystems that many animals depend on. Since many of the remaining roadless areas are so remote and include terrain that is very rugged, the financial cost of development is very high, and the severity of the changes required to add roads and enable development is extreme. I’ve hiked many times in the Jewel Basin hiking area between Bigfork and Hungry Horse Reservoir, and I’ve asked my kids to scatter my ashes there after I’m gone. As a graphic example of what our human activities have done to the terrain, I created the attached Powerpoint slides (for presentation to a high school class) that shows a hillshade of the original vs. developed terrain around Laguna Niguel, California. Development of the landscape for human use is not necessarily bad, but I feel we can afford to limit future development in our existing natural areas. Let’s please continue to protect our fragile and important roadless areas. I oppose the proposal to rescind or alter the Roadless Rule, and support Alternative 1, the No Action alternative.