Comment Analysis · Docket FS-2025-0001

FS-2025-0001-612750

Opposes rescissionA3 weakSubstance 10/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment establishes that the proposal's rationale for rescinding the Roadless Rule is factually inaccurate by citing peer-reviewed research and USDA data showing that roadless areas have lower wildfire burn rates and that existing rules already permit fuel treatments, while documenting specific local impacts on the Flathead National Forest regarding timber economics, road maintenance backlogs, water quality, and wildlife habitat.

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 Analytical gap, 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

Forest Management Wildfire
- “Rescinding the Roadless Rule will accelerate the already increasing frequency of wildfires”
- “Increased roads will mean increased wildfires”
- “The present Rule already allows for fire mitigation treatments”
- “34% of all fuel treatment activities between 2001–2019 occurred in roadless areas”
Wildlife Habitat
- “Roads threaten the populations of both endangered species and species important to recreational hunting and fishing”
- “threats to these fisheries in turn threaten the local economy”
- “Populations of other species important to recreational pursuits such as hunting and wildlife viewing have been to be diminished by roads”
- “Increased roads will also encourage the spread of invasive species”
Water Quality Quantity
- “Recreational and municipal water supplies would be threatened”
- “Roads threaten water quality by causing increased sediment runoff”
- “reduces water storage capacity upstream from municipal systems”
- “threatens local fisheries”
Recreation Tourism Public Use
- “More open roads will mean more motorized recreational access”
- “threaten riparian habitat and the opportunity for quiet recreation”
- “poor road conditions are a persistent barrier to public access for recreation”
- “species important to recreational hunting and fishing”

What it names

National Forests: Flathead National Forest
Works cited: Andrews et al. 2015

Attachments

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

Own letter
Own letter

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeEvidence

1. Rescinding the Roadless Rule will accelerate the already increasing frequency of wildfires rather than contribute to fire mitigation measures as stated in the Proposal. Increased roads will mean increased wildfires; this has been demonstrated on multiple occasions by peer-reviewed research. Ninety percent of wildfires are caused by humans, and 95% of those fires are within one half mile of a road. The reasons for this are many and include discarded cigarettes, campfires, fireworks, equipment malfunction, vehicle-caused sparks, and alteration of the vegetation to more flammable varieties. A recent peer-review article (Aplet, G.H., Hartger, P., & Dietz, M.S. Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. Fire Ecol. 22, 8 (2026). https://doi.org/10.1186/ s42408-026-00450-2) presents data supporting the widely recognized fact that increased roads translate into increased wildfires. Additionally, USDA analysis of wildfires during the decade 2014-2024 shows that only 8.7% of roadless lands burned during that period compared to 14% on other federal lands. The present Rule already allows for fire mitigation treatments; in fact, 34% of all fuel treatment activities between 2001–2019 occurred in roadless areas. Thus, the claim articulated in the proposal that the Rule constrains fire mitigation is untrue. This claim has been suggested as the main rationale for rescinding the rule but is in fact inaccurate and has no functional application. 2. The forests in roadless areas are generally not suitable for timber production. These forests are in remote, steep areas with rocky terrain, making construction of road access difficult, costly, and hard to maintain. The majority of the timber that would be available if new roads were built to access the present roadless areas is frequently of low quality and would require extensive and expensive haul times. This is particularly true on our local forest, the Flathead National Forest (FNF), where proposed timber sales have failed to attract successful bidders; selling only after dramatic reductions in minimum bid price (https://hungryhorsenews.com/news/ 2025/jul/23/expect-more-timber-harvest-on-flathead/). 3. New roads will unavoidably be poorly maintained. Presently, the USFS is responsible for many more miles of road than the Federal Highway Department. They cannot keep up with present road maintenance needs due to staff and budget constraints, with a reported $8 billion maintenance backlog. Currently, the cost of maintaining the 368,000 miles of USFS roads is estimated to be $1.6 billion. In 2025, Congress appropriated only $73 million to road maintenance, roughly 0.5% of the estimated need. This is apparent on the Flathead National Forest, where poor road conditions are a persistent barrier to public access for recreation or to private property contiguous with the USFS lands. 4. Recreational and municipal water supplies would be threatened. Roads threaten water quality by causing increased sediment runoff. This, in turn, endangers municipal water supplies. Increased sediment runoff from roads reduces water storage capacity upstream from municipal systems, resulting in the need for expensive system upgrades. This sediment also threatens local fisheries, including the endangered bull trout and native cutthroat trout. 5. Roads threaten the populations of both endangered species and species important to recreational hunting and fishing. This has been documented in numerous scientific studies. As noted above, roads negatively impact fisheries. Native fish are critical to the local outfitter and guide industry; threats to these fisheries in turn threaten the local economy. Populations of other species important to recreational pursuits such as hunting and wildlife viewing have been to be diminished by roads. These include wolves, grizzly bears, mule deer, cougars, bighorn sheep, and moose. Amphibians, reptiles, and migrating songbirds are also negatively affected. Increased roads will also encourage the spread of invasive species. 6. More open roads will mean more motorized recreational access. This is a poorly policed industry which has caused fatalities in the North Fork of the Flathead River Valley. Recent reductions in agency capacity will further limit law enforcement needed to police increased motorized recreation. This is complicated by the recent explosion in motorized recreation as a result of newer technology designed for on- and off-road use. These technologies threaten riparian habitat and the opportunity for quiet recreation at a time when law enforcement is already compromised.