Comment Analysis · Docket FS-2025-0001

FS-2025-0001-259206

Opposes rescissionA0 noneSubstance 6/24Posted August 23, 2026 On Regulations.gov

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

A0 none: Counted, not answered.

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.
  • Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
  • 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.
  • 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.

Topics

  • Environmental Protection Biodiversity
    • “complex ecosystems they nourish, which simply cannot survive the way they are now if the roadless rule would be rescinded”
    • “habitat fragmentation reduces biodiversity by 13 to 75% and impairs key ecosystem functions”
    • “Interior Forest Habitat for Spotted Owls and Marbled Murrelets”
    • “decline of at least 34 species across all trophic levels”
  • Water Quality Quantity
    • “pristine nature of their waters, to which additional road construction would in fact be detrimental”
    • “roads disrupt soil structures and hydrological pathways”
    • “sedimentation”
    • “pattern of runoff”
  • Recreation Tourism Public Use
    • “As an outdoor enthusiast, I've seen what roads do to a landscape I'd been walking into for years”
    • “They are a place where I can feel more at home than my own home”
    • “I visit them regularly with my partner”
    • “quiet, remote, and backcountry recreation values”

What it names

National Forests
Mt Baker-Snoqualmie National Forest
Roadless areas
Mt. Baker West
Works cited
10.1046/j.1523-1739.2000.99084.x10.17226/1153510.3390/biosphere2010001Haddad et al. 2015

The comment

Dear Chief Schultz, As an outdoor enthusiast, I've seen what roads do to a landscape I'd been walking into for years. The areas within the Mount Baker Snoqualmie National Forest are truly some of the most spectacular places I have seen. They are a place where I can feel more at home than my own home. They are sacred to me, and to so many forms of life. I visit them regularly with my partner, it is a cradle for our love and the love of our Earth. Seeing them threatened, along with so many other treasured landscapes that are nationally protected by the roadless rule, fills my heart with anxiety and my eyes full of tears. One occasion in particular illustrates what that relationship means in practice. The first time I went swimming in the Nooksack, though the Snoqualmie was no less immaculate. These Rivers have cleansed my soul with their waters every time I have visited. Whether I submerge myself or not they have never failed to heal and rejuvenate my heart. It’s not just for the pristine nature of their waters, to which additional road construction would in fact be detrimental, but also for the complex ecosystems they nourish, which simply cannot survive the way they are now if the roadless rule would be rescinded. Everything is connected and all of it can be felt on the banks of each stream, or even just underneath any one of the trees in the forest. The experience recounted and the connection it reflects are offered as evidence that the Rule's continuation serves identifiable, concrete public interests that the present proposal fails adequately to weigh. Regarding the Mt. Baker West in the Mt Baker-Snoqualmie National Forest, Washington: Interior Forest Habitat for Spotted Owls and Marbled Murrelets — The North Pacific Maritime Silver Fir-Western Hemlock and Subalpine Parkland forests provide interior forest conditions required by northern spotted owl (*Strix occidentalis caurina*, federally threatened with critical habitat designation)… “At intermediate scales, roads disrupt soil structures and hydrological pathways and alter plant and animal communities. Chemical pollution from vehicle exhaust (primarily NOX) enriches roadside soil and changes plant composition, favoring a few dominant flowering plants at the expense of more sensitive plant species (for example, ferns, mosses, and lichens). The extent of this effect can range up to 200 m from multilane highways and up to 35 m from two-lane highways. — National Academies Press / Transportation Research Board, 2005 (https://doi.org/10.17226/11535)” “Two centuries of road building, logging, and aggregate mining have contributed to a ~82% (6200 km2) reduction in unlogged, roadless (>1 km from roads) habitat in Algonquin Park at a mean decline rate of 32 km2/yr. There are at least ~5500 km of roads that fragment Algonquin Park into 732 roadless habitats covering 18% of the Park's area. Decline of roadless habitat has contributed to the impairment of ecological integrity and decline of at least 34 species across all trophic levels, including at least 17 species-at-risk. — MDPI / Biosphere, 2026 (https://doi.org/10.3390/biosphere2010001)” “70% of remaining forest is within 1 km of the forest's edge, subject to the degrading effects of fragmentation. A synthesis of fragmentation experiments spanning multiple biomes and scales, five continents, and 35 years demonstrates that habitat fragmentation reduces biodiversity by 13 to 75% and impairs key ecosystem functions by decreasing biomass and altering nutrient cycles. Effects are greatest in the smallest and most isolated fragments, and they magnify with the passage of time, with average species loss >20% after 1 year and >50% after 10 years. — PMC / Science Advances, 2015 (https://doi.org/10.1126/sciadv.1500052)” “Road construction increases soil compaction up to 200 times relative to undisturbed sites, likely decreasing the survival of soil biota. A road transforms the physical conditions on and adjacent to it, creating edge effects with consequences that extend beyond the time of the road's construction. At least eight physical characteristics of the environment are altered by roads: soil density, temperature, soil water content, light, dust, surface-water flow, pattern of runoff, and sedimentation. Long-term use of roads leads to soil compaction that persists even after use is discontinued; the consequences of past sediment delivery are long-lasting and cumulative and cannot be effectively mitigated. — Conservation Biology / Wiley Online Library, 2000 (https://doi.org/10.1046/j.1523-1739.2000.99084.x)” “)” The Rule should remain in full force; the Department is urged to decline the proposed rescission action. Respectfully submitted, CommentID: RLC-20260823-F7M9J8

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