Comment Analysis · Docket FS-2025-0001

FS-2025-0001-609647

Opposes rescissionA1 strongSubstance 14/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents that the DEIS fails to incorporate the USFWS Biological Assessment finding that 60% of taxa are threatened by invasive species and conflicts with Executive Order 13751, while specifically identifying Victor, Idaho, and the Gros Ventre Wilderness as locations where road access exacerbates invasive plant infestations and wildfire risks.

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

A1 strong: Must be answered — it names the law.

Owed an answer on Analytical gap, Evidence, Legal.

Standard dismissals it defeats

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.
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.
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.

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.
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.

Topics

Environmental Protection Biodiversity
- “impacts of invasive plant species”
- “create favorable conditions for invasive plants”
- “60 percent of taxa studied are threatened by invasive or non-native species”
- “functional forest ecosystems are a resource we can't afford to lose”
Legal Regulatory Framework
- “direct conflict with a standing executive order”
- “Executive Order 13751”
- “DEIS does not include this finding”
- “This contradiction must be resolved”
Economic Impact Fiscal
- “threatening the economic viability of the lease”
- “It is an economic disaster happening in slow motion”
- “threaten the economy of our valley”
- “relies heavily on recreational tourism”
Forest Management Wildfire
- “increased wildfire risk”
- “potentially increase wildfire risk”
- “spread to the adjacent Targhee National Forest”

What it names

National Forests: Targhee National Forest
Roadless areas: Wilderness Study Area
Law cited: Executive Order 13751

The comment

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

I object to rescission of the roadless rule and support Alternative 1, no action, due to the impacts of invasive plant species. I live adjacent to public lands in Eastern Idaho and Western Wyoming where invasive plant species have become a serious concern. In my own experience, trails in Wilderness and Wilderness Study Areas like the Gros Ventre Wilderness, Southern Wyoming Range, and Palisades Wilderness Study Area have very few occurrences of species like Musk Thistle, Canada Thistle, and Spotted Knapweed while roads and trails open to motorized use have populations from occasional individuals to full-blown infestation. One grazing lease adjascent to our farm in Victor, Idaho, on BLM land with a road easement through it, is absolutely infested with Musk Thistle, threatening the economic viability of the lease, spread to the adjacent Targhee National Forest, and increased wildfire risk. It is an economic disaster happening in slow motion. For the specifics of the proposed rescission, my objection rests on the fact that Alternatives 2 and 3 would be in direct conflict with a standing executive order. This order, Executive Order 13751, commits agencies to avoid worsening the problem of invasive plant species and the USFWS’s own Biological Assessment makes clear that roads (and their construction) “create favorable conditions for invasive plants by providing light gaps, dispersal corridors, and reduced competition.” This analysis also states that 60 percent of taxa studied are threatened by invasive or non-native species. The DEIS does not include this finding, nor the 60 percent figure. The DEIS openly admits on page 116 that Alternatives 2 and 3 “could potentially increase the extent or the number of incisive plant species in the affected environment area." This contradiction must be resolved. All of this is to say the obvious: roads bring with them invasive plant species that, once established, are very difficult to deal with and cause significant economic damage. In my area, rescission of the roadless rule would threaten the economy of our valley which relies heavily on recreational tourism. It would also potentially increase wildfire risk. Our functional forest ecosystems are a resource we can't afford to lose.