Comment Analysis · Docket FS-2025-0001

FS-2025-0001-268787

Opposes rescissionA2 moderateSubstance 15/24Owed an answerPosted August 25, 2026 On Regulations.gov

In short: The comment places on the record specific data regarding wildfire ignition densities, water intake locations, and economic projections to document deficiencies in the agency's cost-benefit analysis and regulatory flexibility findings, while asserting a personal reliance interest based on ten years of trail maintenance in the Noisy-Diobsud Creek area.

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

A2 moderate: Hard to dismiss — it shows cause and effect.

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.
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.

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.
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

Water Quality Quantity
- “sediment washed in, logging runoff filling streams”
- “trees and vegetation removed that keep water cool and in the ground”
- “1,522 municipal water intakes sit in watersheds containing affected roadless areas”
- “weighs the sediment and runoff consequences of new road construction in these specific watersheds”
Forest Management Wildfire
- “Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas”
- “human-caused ignitions increase in abundance with proximity to roads”
- “road access could increase the number and frequency of wildfires”
- “quantify the expected increase in human-caused ignitions that would follow new road access”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million”
- “expanding a road system already carrying a $6.9 billion maintenance backlog”
- “agency's own numbers cannot establish a net benefit”
Recreation Tourism Public Use
- “peace of the North Cascades trails I have maintained year after year”
- “I hike in and near North Cascades National Park and surrounding areas”
- “I have paddled the Nooksack and Skagit Rivers and their tributaries”
- “Boulder River, which I have visited every year, is a photographer's and nature lover's dream”

What it names

Roadless areas: Boulder RiverMt. Baker SouthMt. Baker West

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The waterfalls tumbling over the ridges of the Boulder River area, the wildflowers in spring, the burning fall colors, the peace of the North Cascades trails I have maintained year after year at Noisy-Diobsud Creek: these places are the reason I am filing this comment opposing the proposed rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001). I hike in and near North Cascades National Park and surrounding areas, I have paddled the Nooksack and Skagit Rivers and their tributaries, and I oppose this proposal on grounds that the agency's own analysis cannot sustain it. The economics here do not add up, and the agency owes the public a clear answer on that. The record before the agency already states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against those figures, the agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service, set against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. The agency must reconcile the proposal with that range, and explain how expanding a road system already carrying a $6.9 billion maintenance backlog is justified when the agency's own numbers cannot establish a net benefit. The fire question is one I think about directly, because I have seen how the trees and vegetation along these streams hold water in the ground and moderate temperature. Roads let in not only machinery but ignition. The agency's own data is stark: "Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014–2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads." The same effects analysis concedes that road access could increase the number and frequency of wildfires. The agency must quantify the expected increase in human-caused ignitions that would follow new road access and weigh that increase against any claimed reduction in wildfire hazard before it finalizes this rule. When I paddle the Nooksack and Skagit and see the wildlife that inhabits these waters, I think about what feeds those rivers. It is heartbreaking to consider roads placed near these waters: sediment washed in, logging runoff filling streams, the trees and vegetation removed that keep water cool and in the ground. Washington holds 139 inventoried roadless areas totaling 2,014,832 acres, and across the Pacific Northwest region 1,522 municipal water intakes sit in watersheds containing affected roadless areas. The Mt. Baker-Snoqualmie roadless areas I care about, including Boulder River at 32,563 acres, Mt. Baker Noisy-Diobsud at 56,039 acres, Mt. Baker West at 25,390 acres, and Mt. Baker South at 6,570 acres, feed those downstream systems. The agency must explain on the record how it weighs the sediment and runoff consequences of new road construction in these specific watersheds against the interests of the communities and ecosystems they supply. The regulatory flexibility finding cannot stand alongside the analysis the agency itself produced. "The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year." The supporting analysis reaches that no-impact conclusion by averaging the loss across every small firm in the sector nationally, rather than looking at the outfitters and guides who actually hold permits in these areas, and it concedes that some firms may lose those receipts entirely. The agency should withdraw that certification and conduct an honest assessment of the businesses actually operating in the potentially affected roadless areas. Finally, I have done yearly trail maintenance at Noisy-Diobsud Creek for over 10 years. Boulder River, which I have visited every year, is a photographer's and nature lover's dream. These are not abstract commitments. "The proposal solicits 'any reliance interests in the current rule that could be affected by this proposal' (91 FR 53830-31), and the Cost Benefit Analysis weighs none." This comment is precisely such a reliance interest, offered in direct response to that solicitation. The agency must identify and genuinely weigh the reliance interests described in the comments it receives, including this one, before it proceeds. Judith Akins Bellingham,WA