Comment Analysis · Docket FS-2025-0001

FS-2025-0001-605454

Opposes rescissionA0 noneSubstance 6/24Posted 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
- “protected watersheds, wildlife corridors, and backcountry character”
- “Roadless areas are, on average, some of the least fire-prone and most fire-resilient forest”
- “New roads fragment habitat, increase sedimentation into the trout streams”
Forest Management Wildfire
- “The wildfire rationale doesn't hold up”
- “vast majority of fire ignitions occur near existing roads, not in the roadless backcountry”
- “Thinning and fuels work can and does already happen inside roadless areas under the existing rule's exceptions”
Recreation Tourism Public Use
- “public access to intact national forest land is not an abstraction”
- “backbone of how this community works, recreates, and makes a living”
- “anchor hunting, fishing, outfitting, and tourism economies”
Governance Policy Process
- “Replacing that consistent nationwide standard with 175 separate forest-plan decisions doesn't reduce regulatory burden”
- “invites the same fights over and over, forest by forest, for decades”
- “roughly 99% of them opposed to rescission”

The comment

Wendy Dodd Emigrant, MT 59027 September 7, 2026 Re: Opposition to the Proposed Rescission of the 2001 Roadless Area Conservation Rule (91 FR 53827) To the U.S. Department of Agriculture and U.S. Forest Service: I am writing as a Montana resident to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. I live in Emigrant, MT, in the shadow of the Absaroka-Beartooth Front, where public access to intact national forest land is not an abstraction — it is the backbone of how this community works, recreates, and makes a living. It is also an area that I frequently bird hunt on with our two dogs. I ask that USDA withdraw this proposal and keep the Roadless Rule in place. The rule has done exactly what it was designed to do. For 25 years, the Roadless Rule has protected roughly 45 million acres of national forest — nearly a third of the entire National Forest System — from new road construction and industrial-scale logging, while still allowing wildfire response, grazing, and recreation to continue. It was never a "lock it up and leave it" rule; it was a bright-line standard that protected watersheds, wildlife corridors, and backcountry character precisely because it applied everywhere the same way. Replacing that consistent nationwide standard with 175 separate forest-plan decisions doesn't reduce regulatory burden — it multiplies it, and it invites the same fights over and over, forest by forest, for decades. The wildfire rationale doesn't hold up. USDA has framed this rescission as a wildfire-prevention measure, but the agency's own data undercuts that argument: the vast majority of fire ignitions occur near existing roads, not in the roadless backcountry the rule protects. Roadless areas are, on average, some of the least fire-prone and most fire-resilient forest in the system. Thinning and fuels work can and does already happen inside roadless areas under the existing rule's exceptions. What rescission actually opens the door to is new permanent and temporary road construction and increased timber harvest — by the Forest Service's own estimate, an additional 4.8 million acres available for logging — which is a very different goal than fire mitigation. Roads are also a proven fire and erosion liability, not just a construction cost. New roads fragment habitat, increase sedimentation into the trout streams and rivers that define places like the Paradise Valley, and create long-term maintenance obligations the Forest Service is already unable to keep up with on its existing 380,000-mile road system. Adding to that backlog rather than maintaining what already exists is not a responsible tradeoff. The public record does not support this rollback. When the Roadless Rule was first opened to rescission in 2005 and again in 2020, the overwhelming majority of public comments favored keeping it intact. USDA's own 2025 scoping period drew more than 220,000 comments, roughly 99% of them opposed to rescission. A "one-size-fits-all" rule that the public has defended this consistently, across administrations, for a quarter century, is not a rule in need of dismantling — it's a rule doing its job. Montana has a direct stake in this decision. Our roadless national forest lands anchor hunting, fishing, outfitting, and tourism economies that don't require a single tree to be cut to generate revenue year after year. Once a road is built and a drainage is opened to industrial use, that backcountry character does not come back. I ask USDA to weigh that permanence against the modest, short-term revenue this rescission is projected to generate. For these reasons, I respectfully urge USDA to withdraw the proposed rescission and retain the 2001 Roadless Area Conservation Rule in its current form. Thank you for considering my comment. Sincerely, Wendy Dodd Emigrant, MT 59027