Comment Analysis · Docket FS-2025-0001

FS-2025-0001-606191

Opposes rescissionA3 weakSubstance 8/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents a specific history of procedural failures in the Crazy Mountains, including NEPA and NHPA violations and lack of tribal consultation, to support the request to retain the 2001 Roadless Area Conservation 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

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

Governance Policy Process
- “consistent pattern of procedural defects in local and project‑level decision‑making”
- “failures to conduct required feasibility analyses, notify tribal governments, or complete NEPA review”
- “systemic weaknesses in transparency, record completeness, and public participation”
- “local and project‑level processes are not sufficient to protect roadless values”
Environmental Protection Biodiversity
- “Sensitive wildlife habitat was not analyzed”
- “expose intact watersheds, wildlife habitat, and culturally significant landscapes”
- “protect roadless values”
- “prevent the types of procedural failures... from determining the fate of roadless landscapes”
Tribal Sovereignty
- “failed to... notify tribal governments”
- “published legal notices only in non‑tribal newspapers, despite the Crazy Mountains being an area of cultural importance to the Crow Tribe”
- “pattern of excluding tribal communities”
- “tribal consultation”
Water Quality Quantity
- “expose intact watersheds”
- “protect roadless values”
- “durable protections”

What it names

Roadless areas: Crazy MountainCrazy Mountains

The comment

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

I oppose rescinding the 2001 Roadless Area Conservation Rule. My position is based on more than twenty years of experience in the Crazy Mountains and six years of documented engagement with Forest Service processes, including formal comments, objections, and correspondence submitted between 2018 and 2024. These materials show a consistent pattern of procedural defects in local and project‑level decision‑making—failures that demonstrate why national‑level roadless protections remain essential. In 2018, I documented that the Forest Service failed to conduct required feasibility analyses, notify tribal governments, or complete NEPA review for the Porcupine Lowline Trail #267 proposal. Landowners had obstructed public access for sixteen years, and the proposed reroute rewarded that obstruction. Sensitive wildlife habitat was not analyzed, and nearly year‑long meetings between the Forest Service and the Crazy Mountain Working Group were not open to the public. These failures showed early and clearly that local processes were vulnerable to non‑transparent decision‑making and inconsistent enforcement of public access rights. In 2019, I documented that the Forest Service failed to conduct required public scoping for the South Crazy Mountains Land Exchange and published legal notices only in non‑tribal newspapers, despite the Crazy Mountains being an area of cultural importance to the Crow Tribe. The preliminary environmental assessment was premature, and the absence of scoping prevented meaningful public participation. These failures demonstrated a pattern of excluding tribal communities and bypassing required NEPA steps. In 2022, I documented that combining scoping with the Preliminary Environmental Assessment for the East Crazy Inspiration Divide (ECID) proposal eliminated meaningful public input and advanced the interests of non‑Federal parties. I also documented that measurable agency action on access issues occurred only after litigation was filed, showing that enforcement of public rights depended on external pressure rather than consistent agency practice. In 2023, I documented that non‑agency groups “masquerading as Federal Advisory Committees” misled the public and convoluted the NEPA process, and that the Forest Service later clarified these groups did not advise the agency, contradicting years of public messaging. I also documented that the Sweet Grass County Commission received the ECID proposal before the Forest Service, that the Crazy Mountain Access Project solicited and analyzed public comment without legal authority, and that a key specialist report (Forestoration Narrative) was withheld until after comment periods closed. These defects demonstrated systemic weaknesses in transparency, record completeness, and public participation. In 2024, I documented that Forest Service communication to Congress omitted substantial public and conservation‑group objection and mischaracterized landowner interests. This showed that procedural irregularities and incomplete disclosures extend beyond NEPA documents and into communications with Congressional oversight bodies. Taken together, these documented failures—spanning NEPA, NHPA, transparency, record completeness, tribal consultation, and public participation—demonstrate that local and project‑level processes are not sufficient to protect roadless values. Removing national‑level safeguards would expose intact watersheds, wildlife habitat, and culturally significant landscapes to decision‑making processes that have already shown systemic weaknesses. The Roadless Rule provides consistent, durable protections that prevent the types of procedural failures documented in the Crazy Mountains from determining the fate of roadless landscapes. For these reasons, I respectfully request that the Forest Service retain the 2001 Roadless Area Conservation Rule. Thank you for considering my comment. Sheila Royston Wilsall, MT