Roadless Rule Public Comment

[Tbar]

Is it odd that Montana fwp said this will negatively impact 90% of their elk herds critical habitat on one way or another.  The word we received from them was broad opposition.  Blind support and topics with myopic viewpoints seems way to normal from both sides of the political spectrum.

Regarding Montana:
Does that change the fact that all of the best producing units in Montana have significant amounts of farming and ranching?
Does it change the fact that the biggest wilderness in Montana has had its elk herd wiped out by predators?

Look at any one of the top producing elk units in Montana and then find the neighboring unit with the least roads and elk harvest will be less than half and sometimes less than 25%. I cannot put much worth in those who say roadless areas hold more animals, the harvest stats just do not support that belief! However, I would fully agree that seasonal road closures in logging areas are a good thing, game animals thrive in logging areas. Another beneficial thing are the farmers and ranchers who do not allow hunting, those are great reservoirs for game to flourish on the agriculture and then spread into other areas where they can be hunted.

Montana's highest producing elk units all have large amounts of private property that are farmed, ranched, have human activity, and thousands of cattle on the landscape. I outfit in one of these units and the best elk hunting in that unit is on private ranch lands with cattle, humans checking the cows on atv's or horses, agricultural crops, and far fewer predators.
Unit 410 - 950 elk
Unit 380 - 795 elk
Unit 411 - 700 elk
Unit 314 - 658 elk
Unit 393 - 565 elk
Unit 360 - 533 elk


The largest wilderness in Montana is the Bob Marshall Wilderness. Together, the Great Bear, Bob Marshall, and Scapegoat Wildernesses form the Bob Marshall Wilderness Complex, an area of more than 1.5 million acres. Here's the elk Harvest in the most roadless units within the Bob Marshal Complex, according to many people this roadless area should be full of elk! I know outfitters, guides, and hunters who hunt these units, there are many hunts that not one elk is seen during the hunt.
Unit 141 - 4 elk
Unit 280 - 17 elk
Unit 424 - 33 elk
Unit 150 - 50 elk
Unit 442 - 103 elk

These wilderness areas could be better hunting again if arial predator management was allowed (there are no roads for other types of predator management). Wildfires do create good habitat, but too many predators prevent herds from recovering. We all enjoy a wilderness experience, and I would never want to see our wildernesses eliminated, but wilderness hunting is simply not as good as it was 50 years ago before the predator craze took over our government agencies.

2024 Harvest Verified Here:  https://myfwp.mt.gov/fwpPub/harvestReports

Critical habitat is not necessarily where harvest occurs and there is concerted efforts to kill elk in conflict zones throughout the west.  Carrying capacity in the interface is set artificially low to accommodate social Carrying capacity which I am sure you at aware and are also a beneficiary through tag allocation.  It would be a much different story if the limited untouched habitat were fragmented.  Time will tell but it seems very short sighted to not recognize the multiple benefits of these(very limited) areas throughout the west.  The benefits will be to very few and the impacts very broad. 
Side note,  did you follow the pebble mine? I only ask because it was the potential devastation of a pristine area and what could potentially occur throughout the west.
  I put a high value on these places and acknowledge the mismanagement that is so prevalent in the current roaded areas.  There is potential to improve without repealing the roadless rule.

[jackelope]

It’s probably fair to say that hunting is almost always better on private ground, isn’t it?  Aka farm land out here in the west? I mean it’s like a gigantic food plot.

[Tbar]

It’s probably fair to say that hunting is almost always better on private ground, isn’t it?  Aka farm land out here in the west? I mean it’s like a gigantic food plot.

I don't disagree but it's dangerous to depend solely on private ground.  Another consideration is alpine species like mountain goats and others.  Those environments are almost exclusively in the roadless area and are proven to be very fragile.  Fragmentation alone can threaten certain species, industrialization could be catastrophic (pebble mine).

[hunter399]

It’s probably fair to say that hunting is almost always better on private ground, isn’t it?  Aka farm land out here in the west? I mean it’s like a gigantic food plot.

Heck ya it is .....lol
I'd bet there is a very high percentage statewide.
If I had to put a number on my area ,I'd say 80 percent of big game animals live on private.

[bearpaw]

Is it odd that Montana fwp said this will negatively impact 90% of their elk herds critical habitat on one way or another.  The word we received from them was broad opposition.  Blind support and topics with myopic viewpoints seems way to normal from both sides of the political spectrum.

Regarding Montana:
Does that change the fact that all of the best producing units in Montana have significant amounts of farming and ranching?
Does it change the fact that the biggest wilderness in Montana has had its elk herd wiped out by predators?

Look at any one of the top producing elk units in Montana and then find the neighboring unit with the least roads and elk harvest will be less than half and sometimes less than 25%. I cannot put much worth in those who say roadless areas hold more animals, the harvest stats just do not support that belief! However, I would fully agree that seasonal road closures in logging areas are a good thing, game animals thrive in logging areas. Another beneficial thing are the farmers and ranchers who do not allow hunting, those are great reservoirs for game to flourish on the agriculture and then spread into other areas where they can be hunted.

Montana's highest producing elk units all have large amounts of private property that are farmed, ranched, have human activity, and thousands of cattle on the landscape. I outfit in one of these units and the best elk hunting in that unit is on private ranch lands with cattle, humans checking the cows on atv's or horses, agricultural crops, and far fewer predators.
Unit 410 - 950 elk
Unit 380 - 795 elk
Unit 411 - 700 elk
Unit 314 - 658 elk
Unit 393 - 565 elk
Unit 360 - 533 elk


The largest wilderness in Montana is the Bob Marshall Wilderness. Together, the Great Bear, Bob Marshall, and Scapegoat Wildernesses form the Bob Marshall Wilderness Complex, an area of more than 1.5 million acres. Here's the elk Harvest in the most roadless units within the Bob Marshal Complex, according to many people this roadless area should be full of elk! I know outfitters, guides, and hunters who hunt these units, there are many hunts that not one elk is seen during the hunt.
Unit 141 - 4 elk
Unit 280 - 17 elk
Unit 424 - 33 elk
Unit 150 - 50 elk
Unit 442 - 103 elk

These wilderness areas could be better hunting again if arial predator management was allowed (there are no roads for other types of predator management). Wildfires do create good habitat, but too many predators prevent herds from recovering. We all enjoy a wilderness experience, and I would never want to see our wildernesses eliminated, but wilderness hunting is simply not as good as it was 50 years ago before the predator craze took over our government agencies.

2024 Harvest Verified Here:  https://myfwp.mt.gov/fwpPub/harvestReports

Critical habitat is not necessarily where harvest occurs and there is concerted efforts to kill elk in conflict zones throughout the west.  Carrying capacity in the interface is set artificially low to accommodate social Carrying capacity which I am sure you at aware and are also a beneficiary through tag allocation.  It would be a much different story if the limited untouched habitat were fragmented.  Time will tell but it seems very short sighted to not recognize the multiple benefits of these(very limited) areas throughout the west.  The benefits will be to very few and the impacts very broad. 
Side note,  did you follow the pebble mine? I only ask because it was the potential devastation of a pristine area and what could potentially occur throughout the west.
  I put a high value on these places and acknowledge the mismanagement that is so prevalent in the current roaded areas.  There is potential to improve without repealing the roadless rule.

While I totally agree that areas for escapement are needed there are ways other than the roadless rule to accomplish that. No matter what arguments you may try, the fact is proven that units with logging, farming, and ranching support more game, and result in more game harvested, it's just a fact.

Look up any wilderness or large roadless area that has no logging, agriculture, or ranching, the herds are smaller than game management units that have logging, agriculture, or ranching. The more you look at the stats and where the herds are actually strongest, the more it proves my point. Go ahead, please prove me wrong?

I won't argue that we need to maintain some wilderness areas for the sake of having wilderness. But don't try to say wilderness supports larger game herds, it simply doesn't.

If hunters want more game, support logging, agriculture, predator management, and by all means demand that there are at least seasonal road closures to provide escapement for wildlife. The trend of diminishing herds can be reversed! But this mistaken idea that untouched land with overage forests is the holy grail of wildlife management is just patently false! That misplaced idealism is what has reduced our game herds and will continue to do so if not reversed!

[bearpaw]

Prevent Conservation Extremism, Maintain Wild Places, Benefit Wildlife, Reduce Fuel For Wildfires, and Maximize Multiple Use On USFS Lands

 - Create a citizen advisory board within each USFS National Forest to maximize the underlined criteria. (one person as recommended by and representing each interest group: USFS, DNR, F&G, Conservation, Logging, Mining, Recreation, Hunting, Ranching)

 - Require checkerboard or wagon wheel style timber sales on 6% to 8% of non-wilderness National Forest lands annually for first 5 years

 - Reassess and adjust: the percentage of annual timber harvest to maximize the core criteria and asses the need and number of USFS employees every 5 years.

 - Require 5 to 20 trees per acre in timber harvest areas to be left for natural reseeding.

 - Implement various types of road closures after timber harvest.

 - Designate 25% of timber sale proceeds for road maintenance and recreational facilities.

[Tbar]

Is it odd that Montana fwp said this will negatively impact 90% of their elk herds critical habitat on one way or another.  The word we received from them was broad opposition.  Blind support and topics with myopic viewpoints seems way to normal from both sides of the political spectrum.

Regarding Montana:
Does that change the fact that all of the best producing units in Montana have significant amounts of farming and ranching?
Does it change the fact that the biggest wilderness in Montana has had its elk herd wiped out by predators?

Look at any one of the top producing elk units in Montana and then find the neighboring unit with the least roads and elk harvest will be less than half and sometimes less than 25%. I cannot put much worth in those who say roadless areas hold more animals, the harvest stats just do not support that belief! However, I would fully agree that seasonal road closures in logging areas are a good thing, game animals thrive in logging areas. Another beneficial thing are the farmers and ranchers who do not allow hunting, those are great reservoirs for game to flourish on the agriculture and then spread into other areas where they can be hunted.

Montana's highest producing elk units all have large amounts of private property that are farmed, ranched, have human activity, and thousands of cattle on the landscape. I outfit in one of these units and the best elk hunting in that unit is on private ranch lands with cattle, humans checking the cows on atv's or horses, agricultural crops, and far fewer predators.
Unit 410 - 950 elk
Unit 380 - 795 elk
Unit 411 - 700 elk
Unit 314 - 658 elk
Unit 393 - 565 elk
Unit 360 - 533 elk


The largest wilderness in Montana is the Bob Marshall Wilderness. Together, the Great Bear, Bob Marshall, and Scapegoat Wildernesses form the Bob Marshall Wilderness Complex, an area of more than 1.5 million acres. Here's the elk Harvest in the most roadless units within the Bob Marshal Complex, according to many people this roadless area should be full of elk! I know outfitters, guides, and hunters who hunt these units, there are many hunts that not one elk is seen during the hunt.
Unit 141 - 4 elk
Unit 280 - 17 elk
Unit 424 - 33 elk
Unit 150 - 50 elk
Unit 442 - 103 elk

These wilderness areas could be better hunting again if arial predator management was allowed (there are no roads for other types of predator management). Wildfires do create good habitat, but too many predators prevent herds from recovering. We all enjoy a wilderness experience, and I would never want to see our wildernesses eliminated, but wilderness hunting is simply not as good as it was 50 years ago before the predator craze took over our government agencies.

2024 Harvest Verified Here:  https://myfwp.mt.gov/fwpPub/harvestReports

Critical habitat is not necessarily where harvest occurs and there is concerted efforts to kill elk in conflict zones throughout the west.  Carrying capacity in the interface is set artificially low to accommodate social Carrying capacity which I am sure you at aware and are also a beneficiary through tag allocation.  It would be a much different story if the limited untouched habitat were fragmented.  Time will tell but it seems very short sighted to not recognize the multiple benefits of these(very limited) areas throughout the west.  The benefits will be to very few and the impacts very broad. 
Side note,  did you follow the pebble mine? I only ask because it was the potential devastation of a pristine area and what could potentially occur throughout the west.
  I put a high value on these places and acknowledge the mismanagement that is so prevalent in the current roaded areas.  There is potential to improve without repealing the roadless rule.

While I totally agree that areas for escapement are needed there are ways other than the roadless rule to accomplish that. No matter what arguments you may try, the fact is proven that units with logging, farming, and ranching support more game, and result in more game harvested, it's just a fact.

Look up any wilderness or large roadless area that has no logging, agriculture, or ranching, the herds are smaller than game management units that have logging, agriculture, or ranching. The more you look at the stats and where the herds are actually strongest, the more it proves my point. Go ahead, please prove me wrong?

I won't argue that we need to maintain some wilderness areas for the sake of having wilderness. But don't try to say wilderness supports larger game herds, it simply doesn't.

If hunters want more game, support logging, agriculture, predator management, and by all means demand that there are at least seasonal road closures to provide escapement for wildlife. The trend of diminishing herds can be reversed! But this mistaken idea that untouched land with overage forests is the holy grail of wildlife management is just patently false! That misplaced idealism is what has reduced our game herds and will continue to do so if not reversed!

How much does the roadless rule constrict the landscape that the USFS manages? Could an amended LSR map accomplish more? Where did I say anything is the holy grail of anything,  the reality is conservation is incredibly difficult on a settled landscape and each element has an increased value largely due to their limited nature. 

 Is hunting best under high fence? Why limit it to private? I can tell you I've been on multiple high fence operations and it's damn good hunting,  fact.

[bearpaw]

Is it odd that Montana fwp said this will negatively impact 90% of their elk herds critical habitat on one way or another.  The word we received from them was broad opposition.  Blind support and topics with myopic viewpoints seems way to normal from both sides of the political spectrum.

Regarding Montana:
Does that change the fact that all of the best producing units in Montana have significant amounts of farming and ranching?
Does it change the fact that the biggest wilderness in Montana has had its elk herd wiped out by predators?

Look at any one of the top producing elk units in Montana and then find the neighboring unit with the least roads and elk harvest will be less than half and sometimes less than 25%. I cannot put much worth in those who say roadless areas hold more animals, the harvest stats just do not support that belief! However, I would fully agree that seasonal road closures in logging areas are a good thing, game animals thrive in logging areas. Another beneficial thing are the farmers and ranchers who do not allow hunting, those are great reservoirs for game to flourish on the agriculture and then spread into other areas where they can be hunted.

Montana's highest producing elk units all have large amounts of private property that are farmed, ranched, have human activity, and thousands of cattle on the landscape. I outfit in one of these units and the best elk hunting in that unit is on private ranch lands with cattle, humans checking the cows on atv's or horses, agricultural crops, and far fewer predators.
Unit 410 - 950 elk
Unit 380 - 795 elk
Unit 411 - 700 elk
Unit 314 - 658 elk
Unit 393 - 565 elk
Unit 360 - 533 elk


The largest wilderness in Montana is the Bob Marshall Wilderness. Together, the Great Bear, Bob Marshall, and Scapegoat Wildernesses form the Bob Marshall Wilderness Complex, an area of more than 1.5 million acres. Here's the elk Harvest in the most roadless units within the Bob Marshal Complex, according to many people this roadless area should be full of elk! I know outfitters, guides, and hunters who hunt these units, there are many hunts that not one elk is seen during the hunt.
Unit 141 - 4 elk
Unit 280 - 17 elk
Unit 424 - 33 elk
Unit 150 - 50 elk
Unit 442 - 103 elk

These wilderness areas could be better hunting again if arial predator management was allowed (there are no roads for other types of predator management). Wildfires do create good habitat, but too many predators prevent herds from recovering. We all enjoy a wilderness experience, and I would never want to see our wildernesses eliminated, but wilderness hunting is simply not as good as it was 50 years ago before the predator craze took over our government agencies.

2024 Harvest Verified Here:  https://myfwp.mt.gov/fwpPub/harvestReports

Critical habitat is not necessarily where harvest occurs and there is concerted efforts to kill elk in conflict zones throughout the west.  Carrying capacity in the interface is set artificially low to accommodate social Carrying capacity which I am sure you at aware and are also a beneficiary through tag allocation.  It would be a much different story if the limited untouched habitat were fragmented.  Time will tell but it seems very short sighted to not recognize the multiple benefits of these(very limited) areas throughout the west.  The benefits will be to very few and the impacts very broad. 
Side note,  did you follow the pebble mine? I only ask because it was the potential devastation of a pristine area and what could potentially occur throughout the west.
  I put a high value on these places and acknowledge the mismanagement that is so prevalent in the current roaded areas.  There is potential to improve without repealing the roadless rule.

While I totally agree that areas for escapement are needed there are ways other than the roadless rule to accomplish that. No matter what arguments you may try, the fact is proven that units with logging, farming, and ranching support more game, and result in more game harvested, it's just a fact.

Look up any wilderness or large roadless area that has no logging, agriculture, or ranching, the herds are smaller than game management units that have logging, agriculture, or ranching. The more you look at the stats and where the herds are actually strongest, the more it proves my point. Go ahead, please prove me wrong?

I won't argue that we need to maintain some wilderness areas for the sake of having wilderness. But don't try to say wilderness supports larger game herds, it simply doesn't.

If hunters want more game, support logging, agriculture, predator management, and by all means demand that there are at least seasonal road closures to provide escapement for wildlife. The trend of diminishing herds can be reversed! But this mistaken idea that untouched land with overage forests is the holy grail of wildlife management is just patently false! That misplaced idealism is what has reduced our game herds and will continue to do so if not reversed!

How much does the roadless rule constrict the landscape that the USFS manages? Could an amended LSR map accomplish more? Where did I say anything is the holy grail of anything,  the reality is conservation is incredibly difficult on a settled landscape and each element has an increased value largely due to their limited nature. 

 Is hunting best under high fence? Why limit it to private? I can tell you I've been on multiple high fence operations and it's damn good hunting,  fact.

The roadless rule in and of itself is limiting, a simple truth.

Didn't accuse you personally of saying "holy grail", simply said "this mistaken idea that untouched land with overage forests is the holy grail of wildlife management is just patently false!".

I believe high fence has its place, I have also done it, but that's a completely separate issue and discussion, I suspect there is 0% support for that on public lands.

[timberfaller]

Received this in a email today, happened in September.  Pay attention to those who are against!!  Same ole nuts from the 80's plus some "local" nuts!  The Methow has their "nuts" too! called the MVCC!


Have you ever walked into an event or meeting and realized immediately you’re the odd one out? That was me at Wild Montana recent Roadless Rule Community Conversation at a local bar, right down the street from my office. Wild Montana (formerly Montana Wilderness Association) is a grassroots conservation organization founded by a group of outfitters, ranchers, doctors, and friends. In Washington, their chapter is known as Washinton Wild.

Unlike the Zoom or Teams meetings I usually attend with multi-recreation groups, this one was in person—just five minutes from my office. I attended because I felt responsible for representing motorized recreation, even if it meant being the lone voice in the room. Just because I am in a different state doesn’t mean the issues change, just the trails, systems, and mountains. No other motorized person was there despite it being widely advertised on Facebook Events as "Learn About The Roadless Rule".

My primary intention in attending this meeting was to listen. If nothing else, hearing how the conservation community frames the Roadless Rule debate helps our side understand what messages are circulating at their events. This work isn’t about thanks or credit—I volunteer my time because I believe motorized recreation deserves a seat at the table in conversations that directly affect access. If attending helps these groups see that our perspective exists—that people do recreate differently but still care deeply about public lands—then it’s worth it.

The crowd, led by Wild Montana and joined by representatives from the Sierra Club, Montana Wildlife Federation, Montana Rural Water Systems, and even a former timber worker, was focused on what they see as the dangers of repealing the Roadless Rule. Their arguments tied roads directly to wildfire risk, environmental damage, and financial strain. Some of the key talking points included:
Fire risk: Claims that 88–90% of wildfires start near roads.
Cost burden: The Forest Service is already $8 billion behind in road maintenance. More roads equal more costs.
Wildlife impacts: New roads fragment habitat for elk, grizzlies, wolverines, and other species.
Water quality: Tire particles and road crossings can pollute streams.
Access problems: Poor Road conditions damage vehicles and strain limited budgets.
For them, the repeal of the Roadless Rule represents not an opportunity but a threat: a corporate land grab, increased logging, and permanent damage to iconic mountain ranges.

When they passed the microphone around for questions, you bet I grabbed it, because why wouldn’t I? I raised questions about access for those with mobility challenges, about how real the tire-particle issue is, about what’s lost for local control if the rule stays in place, tourism dollars, and their wildfire claims. Responses leaned heavily on the idea that motorized users aren’t truly losing access, that fire science backs up their concerns, and that long-term costs justify restrictions. On other issues—like quantifying tire contamination—they had no clear answers, no hardcore science data that they could share.

The formal program wrapped up, but the after-hours debates were where things got real. A few attendees came up to me and wanted to press the issues further, sometimes argumentatively. Hey, I’ve dealt with bullies before; they’re usually all bark, no bite, and honestly, they just end up looking pathetic and desperate in the end. Their arguments held little meaning. They are pushing fear over facts and utilizing their audience's feelings to gain financial ground.
We circled familiar sticking points before ending with the old “agree to disagree.” I left with a mix of frustration, a few recommended white papers on wildlife and interactions with humans, economics books, and a good reminder of how differently we view the same landscapes. I dissected the recommended wildlife studies and found huge holes in their studies. I sure am glad they gave me the ammunition to poke holes in their scientific studies for the next seasonal closure that is handed to us!

In conclusion, here’s the truth: standing alone in a room like that isn’t easy. But if we want motorized recreation to be considered in land-use decisions, we can’t shy away from these conversations. We have to understand how opposing groups motivate their supporters and frame their messages, because those narratives reach decision-makers and the broader public. Listening—really listening—even when it’s tough, matters.
Because even if you’re the one voice in the room, being present means that voice exists.

[cjjcb]

As I understand it, the current roadless rule protects 58.5 million acres from road construction, reconstruction, timber harvest, and mining, among other activities. I’m resistant to taking a 30,000'-view which results in opening the entire 58.5 million. I‘m concerned with this approach; a portion of our public lands could be privatized right out from under us.

How much of this currently protected acreage can be used for the activities listed above? If a section of protected land is not economically viable and no one is pushing to develop, why remove protection? I’m not pro keeping all 58.5 million closed, but we shouldn’t just blanket open all of it either. It doesn’t have to be all or nothing.

Here’s a map of currently protected lands.
https://www.arcgis.com/apps/instant/basic/index.html?appid=bffb3fe5fdfb43519a84c6a0cf4f8ff5

When I was looking around WA state at protected lands I’m familiar with, it’s not hard to find areas I would bet are just not economically viable and no company would even waste time trying. So again, why remove protections here?

If there are any companies or government agencies wanting to get into these areas to start any of the currently restricted activities, I think they should submit a proposal to a bipartisan oversight review board for a due diligence report. If the proposal checks all the boxes, then away they go.

As previously stated, my biggest concern is losing public land. I just think we need to proceed cautiously on this one.