Comment Analysis · Docket FS-2025-0001

FS-2025-0001-593004

Supports rescissionA3 weakSubstance 11/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment documents that the Roadless Rule bypasses Congressional wilderness designation, cites National Visitor Use Monitoring Program data showing less than 1% of recreation use in Payette National Forest wilderness areas, and asserts that the collaborative access process is flawed and dominated by a small minority of stakeholders.

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

Public Land Access Rights
- “kept open to public access, logging, and recreational use and development”
- “increasing roaded recreation”
- “better, fairer access strategy”
- “opportunity for multiple use is very limited and restricted”
Governance Policy Process
- “bypassed the official Congressional designation of Wilderness”
- “collaborative process needs to be restructured”
- “dominated by payed environmental groups, tribes, and likeminded members”
- “returned to General Forest designation”
Recreation Tourism Public Use
- “Recreational businesses in these areas are very depressed”
- “leading to overcrowding and overuse”
- “only five thousand visits were in the wilderness”
- “distribution of recreation use”
Forest Management Wildfire
- “manage fires without portal access roads”
- “extremely steep rugged mountainous terrain”
- “very difficult to access and manage fires”

What it names

National Forests: Payette National Forest

Attachments

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

Own letter

The comment

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

RIN 0596-AD66, https://www.regulations.gov, identified by docket number FS-2025-0001 or RIN 0596-AD66. I support the Rescission of the Roadless Rule! The Roadless Rule bypassed the official Congressional designation of Wilderness under the Wilderness Act of 1964. These quasi-Wilderness areas have been essentially managed as Wilderness. Millions if not billions of dollars have been spent on closing, re-contouring, removing culverts and bridges, and gating roads in these areas. Until Roadless areas are designated by Congress as Wilderness, they should be returned to General Forest designation and kept open to public access, logging, and recreational use and development. In context to the amount of Wilderness and Roadless Areas in our National Forests, they are disproportionate to the amount of non-wilderness in acres and use. Wilderness and Roadless Areas make up nearly ½ of all National Forest lands, totaling 46 to 48 %. Of that, total Roadless areas are shown to be 58.2 million acres which is 30 % of all National Forest land. The National Visitor Use Monitoring Program shows that only 9 percent of Recreation use occurs in the Wilderness of the United States. Even more revealing is the Visitor use on the Payette National Forest of Idaho, my home forest. Wilderness area on the Payette National Forest occupies 790,000 acres or about 1/3 of the Forest. Of the 519,000 visits on the Payette National Forest in the 2018 monitoring year, only five thousand visits were in the wilderness. That is a 0.96 % use rate, or less than 1 %. Designated Roadless occupies 1.7 million acres. Combined, Wilderness and Roadless designation makes up 74% of the total Forest acres. If those numbers hold true, 514,000 visits occur on 26 percent of the Payette National Forest, leading to overcrowding and overuse. As a result, the opportunity for multiple use is very limited and restricted. Recreational businesses in these areas are very depressed. I am very much in favor of rescission of the Roadless rule, and increasing roaded recreation. In addition, I challenge the statement that 0.5 to 1 mile per section of roads exists within our national forest system. If 74% of the forest is Roadless or Wilderness designation, this statement cannot be true. This measure is misleading and unreasonable. The numbers above do not support that statement. In addition, I would support rescission of the Roadless Rule in Idaho. As a retiree Forest Service employee, I volunteered to be an Access Management Collaborative Team Member. The process that I was a part of is flawed and dominated by payed environmental groups, tribes, and likeminded members that have closed most of Forest Service designated roads on the Payette National Forest. Membership and goals of these groups represent only a small percentage of the population of Idaho and the nation. As an example, the Nez Perce Tribe only has 3,500 designated members. The collaborative process needs to be restructured. The roads that remain open on the Payette National Forest resulting from these collaborative processes are the ones protected by law and managed by the County. These roads access communities and are primarily “pass through” travel ways. This road strategy does not support distribution of recreation use or development of reasonable forest access portals. The current (and past) collaborative processes provide very little if any multiple use access. Nearly all Forest Service Roads built for logging, which cost millions of dollars to construct, have been closed. Our Roadless areas are extremely steep rugged mountainous terrain. They are very difficult to access and manage fires without portal access roads. These Roadless Areas are beyond most people’s capabilities to physically access. The extremely low use rates support this reality. We the public need a better balance. Thank you for the opportunity to comment. I hope these comments are seriously considered and a better, fairer access strategy can be developed for the rest of the 1.7 million Idahoans, and nearly 350 million US citizens, rather than those represented in these collaborative groups.