Comment Analysis · Docket FS-2025-0001

FS-2025-0001-260852

Opposes rescissionA2 moderateSubstance 11/24Owed an answerPosted August 23, 2026 On Regulations.gov

In short: The comment establishes that the DEIS lacks site-specific analysis of ecosystem modifications affecting Suckley's Cuckoo Bumble Bee in the Secesh Inventoried Roadless Area, and requests that the 2001 Roadless Rule remain in effect.

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

A2 moderate: Hard to dismiss — it shows cause and effect.

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.
  • 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.

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.
  • 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

  • Wildlife Habitat
    • “Suckley's Cuckoo Bumble Bee (Bombus suckleyi, G2) in the Secesh Inventoried Roadless Area”
    • “loses its primary buffer against 7.3 - Other ecosystem modifications”
    • “Road construction fundamentally alters this baseline”
    • “watching salmon spawn near Warm Lake”
  • Recreation Tourism Public Use
    • “spends time in the backcountry”
    • “backpacking trail I planned my first solo backpacking trip on”
    • “spend multiple days backpacking without seeing another soul”
    • “wild and beautifully preserved”
  • Legal Regulatory Framework
    • “NEPA requires the agency to take a hard look”
    • “The DEIS fails this standard”
    • “Without the protections of the 2001 Roadless Area Conservation Rule”
    • “Department should allow the 2001 Rule to stand”

What it names

National Forests
Payette National Forest
Roadless areas
Secesh

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapAlternative

To the Roadless Rule Rulemaking Docket: For someone who spends time in the backcountry and knows what road access does to a landscape over time, this proposed rescission is the kind of decision that looks different in hindsight than it does on paper today. The Secesh has influenced and shaped me as a person more than I thought possible. It's also in the woods where I grew up, horseback riding as a kid in Idaho, and watching salmon spawn near Warm Lake. I can point to one experience that captures all of it. The Secesh River is the backpacking trail I planned my first solo backpacking trip on, with my soul dog, Chief. This trail is so wild and beautifully preserved because it only has one dirt road that you have to drive multiple hours down in order to access it. I was able to spend multiple days backpacking without seeing another soul, while feeling safe at the same time due to the Forest Service management log at the trailhead. That relationship to these lands is not peripheral to this proceeding — it is the substance of the public interest the Department is obligated to weigh. Regarding the Secesh in the Payette National Forest, Idaho: Without the protections of the 2001 Roadless Area Conservation Rule, Suckley's Cuckoo Bumble Bee (Bombus suckleyi, G2) in the Secesh Inventoried Roadless Area, Payette National Forest, loses its primary buffer against 7.3 - Other ecosystem modifications, assessed at Extreme or 71-100% pop. decline severity across Restricted (11-30%) scope. The persistence of Suckley's Cuckoo Bumble Bee in Secesh under current threat levels presumes continued roadless conditions. Road construction fundamentally alters this baseline, converting the landscape from one that constrains 7.3 - Other ecosystem modifications to one that accelerates it. NEPA requires the agency to take a hard look at the effects of rescission on Suckley's Cuckoo Bumble Bee (Bombus suckleyi) in the Secesh IRA. The DEIS fails this standard without site-specific analysis of 7.3 - Other ecosystem modifications at the severity and scope documented by NatureServe. "Grazing by domestic herbivores is the most widespread land use on the planet, and also a major global change driver in grasslands. We show that aridity partly explains the responses of biodiversity and multifunctionality to long-term livestock grazing. Grazing greatly reduced biodiversity and multifunctionality in steppes with higher aridity, while had no effects in steppes with relatively lower aridity. Long-term grazing had no effects in meadow steppes with relative lower aridity, but reduced biodiversity and multifunctionality in desert steppes with higher aridity." — Nature Communications, 2023 Rescission is unwarranted; the Department should allow the 2001 Rule to stand. With determination, CommentID: RLC-20260823-SU0EAT

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