Comment Analysis · Docket FS-2025-0001

FS-2025-0001-486495

Opposes rescissionA3 weakSubstance 11/24Owed an answerPosted September 28, 2026 On Regulations.gov

In short: The comment establishes that the programmatic analysis is insufficient because it fails to evaluate specific '7.3 - Other ecosystem modifications' impacts to the Suckley's Cuckoo Bumble Bee in the Cube Iron-Silcox IRA, citing scientific evidence that roads alter habitat function and threaten sensitive species.

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

  • Wildlife Habitat
    • “critical habitats for big game, small game and many hundreds non-game terrestrial species”
    • “quality aquatic habitat that remains for sensitive aquatic species such as bull trout, westslope cutthroat trout and rocky tailed frogs”
    • “Suckley's Cuckoo Bumble Bee (Bombus suckleyi, G2)”
    • “distance to unpaved road was the model that most influenced daily nest survival”
  • Environmental Protection Biodiversity
    • “qualitative difference between roaded and roadless terrain is not a matter of preference but of habitat function”
    • “ecosystem services these roadless landscapes provide”
    • “Roads change forests in ways that can't be reversed on a human timescale”
    • “7.3 - Other ecosystem modifications requires infrastructure access to operate at scale”
  • Recreation Tourism Public Use
    • “decades of pursuing game and wild fish on national forest lands”
    • “hiking, hunting and fishing the Cube Iron-Silcox Roadless areas”
    • “lose the solitude, immense beauty”
    • “memories of these roadless wild landscapes”
  • Water Quality Quantity
    • “quality aquatic habitat”
    • “sensitive aquatic species”
    • “fisheries technician and fisheries biologist”
    • “conserve the species that have lived in them”

What it names

National Forests
Lolo National Forest
Roadless areas
Cube Iron - Silcox

The comment

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

Dear Secretary Rollins and Chief Schultz: In my decades of pursuing game and wild fish on national forest lands, I have observed that the qualitative difference between roaded and roadless terrain is not a matter of preference but of habitat function, and the 2001 Rule preserves that function at the regulatory level. I spent many hundreds of days hiking , hunting and fishing the Cube Iron-Silcox Roadless areas as well as many other roadless area in Montana, Idaho, Colorado and New Mexico. As a fisheries technician and fisheries biologist I have dedicated my life and have spent an equal amount of time within these landscapes working to study and conserve the species that have lived in them since time immemorial. I have many memories of these roadless wild landscapes that I will never forget. They support critical habitats for big game, small game and many hundreds non-game terrestrial species. Roadless lands supports most of the quality aquatic habitat that remains for sensitive aquatic species such as bull trout, westslope cutthroat trout and rocky tailed frogs; among any other native species. Don’t let this greedy corrupt admission overturn the roadless rule to make a few wealth sycophants even richer. Hand off! We as the public will lose the solitude, immense beauty, critical wild and fish habitat and the ecosystem services these roadless landscapes provide. Once the roads are built the land is not the same…and doing it under the guise of fire suppression is cheap and fake joke developed by those well connected-wealthy opportunists that want to profit off our public land and those that support the corrupt criminals that current “lead” our government. Regarding the Cube Iron - Silcox in the Lolo National Forest, Montana: Suckley's Cuckoo Bumble Bee (Bombus suckleyi), ranked G2 by NatureServe and federally listed (PE), is present in the Cube Iron - Silcox IRA, Lolo National Forest, where it confronts 7.3 - Other ecosystem modifications at Extreme or 71-100% pop. decline severity across Restricted (11-30%) scope. 7.3 - Other ecosystem modifications requires infrastructure access to operate at scale. Roads are the prerequisite — they deliver the machinery, chemical inputs, and repeated human intrusion that transform this threat from latent to active in areas like Cube Iron - Silcox. A programmatic analysis is insufficient. The DEIS must evaluate 7.3 - Other ecosystem modifications impacts to Suckley's Cuckoo Bumble Bee (Bombus suckleyi, G2) at the scale of the Cube Iron - Silcox Inventoried Roadless Area, Lolo National Forest, with specificity adequate to inform the decision. "From a sample of 463 nests of 17 songbird species, we evaluated how landscape features (distance to forest edge, unpaved roads, and power lines) influenced daily nest survival. For all nesting species combined, distance to unpaved road was the model that most influenced daily nest survival. Numerous nest predators, including brown-headed cowbirds, mammalian mesopredators, and snakes, have been shown to preferentially occupy habitat edge over interior. Rat snakes were frequently associated with road edges, indicating that not all edges are functionally similar." — Ecology and Evolution (PMC), 2014 Roads change forests in ways that can't be reversed on a human timescale. The rule that has prevented that from happening in these areas should stay in place. All the best, Jason CommentID: RLC-20260926-T1Y8UH

Keep learning. Keep speaking up.The Roadless Rule depends on public engagement. Share what you've learned.

© 2026 roadless.org - Defending America's Last Wild Forests

Privacy Policy|Questions or concerns? noroads@roadless.org|Follow us: @defendroadless