Comment Analysis · Docket FS-2025-0001

FS-2025-0001-224392

Opposes rescissionA1 strongSubstance 18/24Owed an answerPosted August 20, 2026 On Regulations.gov

In short: The comment establishes that the Draft EIS fails to provide a watershed-scale aquatic effects analysis for ESA-listed salmonids in the Nooksack and Skagit watersheds, specifically regarding bull trout, Chinook, and steelhead, and requests the disclosure of the methodology behind the $6.1 million annual recreation loss estimate.

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

Water Quality Quantity
- “sediment delivery, altered hydrology, and elevated stream temperature”
- “cold, low-sediment headwater habitat”
- “chronic sediment source”
- “watershed-scale aquatic effects analysis”
Wildlife Habitat
- “ESA-listed salmonids”
- “Bull trout... listed as threatened”
- “Chinook and steelhead... ESA-listed”
- “critical habitat primary constituent elements”
Legal Regulatory Framework
- “complete ESA Section 7 consultation”
- “substantive requirements of the Endangered Species Act”
- “Draft Environmental Impact Statement”
- “retain 36 CFR part 294, subpart B”
Recreation Tourism Public Use
- “recreation losses at 'an estimated $6.1 million annually'”
- “national outdoor recreation sector”
- “non-market and passive use values”

What it names

Roadless areas: South Fork
Law cited: 36 CFR part 294

The comment

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

Comment on Proposed Rescission of the 2001 Roadless Area Conservation Rule Docket: FS-2025-0001 | RIN: 0596-AD66 | 91 FR 53827 (Aug. 20, 2026) I am a resident of Whatcom County, Washington. I fish the Nooksack and Skagit systems, and I do riparian restoration work on a salmon-bearing tributary in the Tenmile watershed with the Whatcom Conservation District. I oppose the proposed rescission and urge the Department to select the No Action alternative. I am writing to identify one specific and serious gap in the Draft Environmental Impact Statement, and to request the methodology behind one economic figure. The DEIS contains no watershed-scale aquatic effects analysis for ESA-listed salmonids. The DEIS concludes that the proposed rule "is not expected to have a significant change to the commercial fishing or fish-processing industries" and offers no meaningful analysis of effects on listed salmonids in Puget Sound watersheds. That conclusion is not supported by the record, and it is inconsistent with the agency's own prior analysis. Road construction, reconstruction, and associated harvest are among the best-documented sources of sediment delivery, altered hydrology, and elevated stream temperature in Pacific Northwest forested watersheds. The Forest Service compiled that record itself in the 2001 Roadless Rule Final EIS, where protection of high-quality headwater watersheds was a central justification for the rule. The Department cannot rescind a rule premised in part on aquatic protection without addressing the aquatic analysis it previously relied on. In the inventoried roadless areas of the Mount Baker-Snoqualmie National Forest, three points require analysis that the DEIS does not provide: Bull trout. The Coastal-Puget Sound distinct population segment is listed as threatened, with designated critical habitat overlapping IRAs in the Nooksack and Skagit drainages. Bull trout are among the most thermally sensitive salmonids in North America and depend on cold, low-sediment headwater habitat of exactly the type these IRAs contain. The DEIS does not analyze effects on critical habitat primary constituent elements. Chinook and steelhead. Puget Sound Chinook and Puget Sound steelhead are both ESA-listed. The North Fork and South Fork Nooksack support the last remaining early-timed Chinook populations in the basin. These are a recovery priority and are already sediment and temperature limited. Additional road-derived sediment in the upper watershed acts on populations with no margin. Northwest Forest Plan Aquatic Conservation Strategy. Many of these IRAs sit within Key Watersheds and Riparian Reserves. The DEIS does not analyze how rescission interacts with ACS objectives or with the watershed condition and road density standards that follow from them. I request that the Department prepare a watershed-scale aquatic effects analysis for the Pacific Northwest region and complete ESA Section 7 consultation with NMFS and USFWS on this programmatic action before issuing a final rule. The statement that local decisions "would remain subject to the substantive requirements of the Endangered Species Act" does not discharge the obligation to analyze the effects of the decision being made now. I would add one point the DEIS raises against itself. It acknowledges a $6.9 billion deferred maintenance backlog for roads and bridges. An unmaintained forest road is not a management tool. It is a chronic sediment source and a failure liability, and the agency's own budget history indicates new roads will join that backlog rather than clear it. The DEIS estimates recreation losses at "an estimated $6.1 million annually." That is roughly fourteen cents per acre per year across 44 million acres, against a national outdoor recreation sector the Bureau of Economic Analysis places near $1.2 trillion in output. The Department has asked commenters for data and analytic methods. I ask the same of the Department: disclose the valuation model, the unit values applied, the source study, and the treatment of non-market and passive use values. As presented, the figure cannot be evaluated or challenged, which is itself a defect in the disclosure. Requested action - Select the No Action alternative and retain 36 CFR part 294, subpart B. - At minimum, prepare a supplemental DEIS containing a watershed-scale aquatic effects analysis for ESA-listed salmonids in the Pacific Northwest, and complete Section 7 consultation. - Disclose the methodology underlying the recreation valuation. - Extend the comment period. Thirty days is not commensurate with a rulemaking affecting 44 million acres.