Comment Analysis · Docket FS-2025-0001

FS-2025-0001-295688

Opposes rescissionA2 moderateSubstance 15/24Owed an answerPosted September 1, 2026 On Regulations.gov

In short: The comment places on the record specific data from the agency's DEIS Table 21 regarding human-caused ignition densities, identifies 1,522 municipal water intakes in affected watersheds, and documents a gap in the regulatory flexibility analysis by arguing that the no-significant-impact certification fails to assess impacts on specific small entities in the affected areas.

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

Recreation Tourism Public Use
- “Access to quiet, healthy, remote forests is directly connected to my health and well-being”
- “opportunity to hike and camp in the Mt. Baker-Snoqualmie National Forest”
- “places people can go to connect with nature and natural beauty, away from roads”
- “lost recreation benefit at a minimum of $6.1 million a year”
Water Quality Quantity
- “Access to clean water is a basic human right”
- “1,522 municipal water intakes sit in watersheds containing affected roadless areas”
- “Roads lead to increased pollution and threaten public health and wellness”
- “roads and their facilities can produce up to 90 percent of the sediment from a timber sale”
Forest Management Wildfire
- “Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “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”
- “agency has not quantified the expected increase in human-caused ignitions from new road access”
Governance Policy Process
- “regulatory flexibility analysis reaches a no-significant-impact conclusion by spreading an estimated $9 million annual expenditure loss”
- “agency must identify and weigh the reliance interests described in the comments”
- “An agency changing course must assess the reliance interests its prior policy created”
- “I ask that the agency explain why the proposal departs from this finding”

What it names

Roadless areas: Boulder RiverHiggins MountainMt. Baker SouthMt. Baker West

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Access to quiet, healthy, remote forests is directly connected to my health and well-being, and the opportunity to hike and camp in the Mt. Baker-Snoqualmie National Forest matters to me in ways that are not abstract. The roadless areas I use, including Mt. Baker Noisy-Diobsud at 56,039 acres, Boulder River at 32,563 acres, Mt. Baker West at 25,390 acres, Pressentin at 14,545 acres, Higgins Mountain at 13,185 acres, and Mt. Baker South at 6,570 acres, are places people can go to connect with nature and natural beauty, away from roads and other forms of civilization and urbanization. Destroying these places with roads would have negative effects not only on the ecosystems but also on my personal mental health and well-being as someone who frequently recreates there. I oppose the rescission of the 2001 Roadless Area Conservation Rule. Washington holds 139 inventoried roadless areas totaling 2,014,832 acres. The proposal would expose all of them to road construction, including the areas I have named. The agency defends rescission in part on wildfire and fuels management grounds, but its own draft environmental impact statement states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." That finding sits in the same record as the proposal to eliminate the protections that kept roads out. I ask that the agency explain why the proposal departs from this finding, and reconcile the rescission with the ignition data in its own DEIS Table 21. The same ignition data makes the contradiction precise: "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 forests I hike in are part of the Pacific Northwest region where I depend on these landscapes remaining unroaded and intact. The agency has not quantified the expected increase in human-caused ignitions from new road access or weighed that increase against the claimed reduction in wildfire hazard. It must do so. Access to clean water is a basic human right and one the government should be striving to protect. Across the Pacific Northwest region, which includes Washington, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. Roads lead to increased pollution and threaten public health and wellness. As drought conditions become more common in the American West, we cannot thoughtlessly contaminate more of our precious drinking water by building roads through important watersheds. The agency's own analysis states that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. The agency must address, specifically and on the record, what the rescission means for the 1,522 intakes in the Pacific Northwest region and the communities downstream of the roadless areas in Washington. The proposal's regulatory flexibility analysis reaches a no-significant-impact conclusion by spreading an estimated $9 million annual expenditure loss across every small firm in the sector nationally rather than examining the outfitters, guides, and tour operators actually holding permits in the affected areas. The agency's own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year, and the analysis concedes some firms may lose these receipts entirely. That certification cannot stand alongside the analysis that produced it. I ask that the agency withdraw the certification and assess impacts on the small entities actually operating in the potentially affected roadless areas, not the national average firm. Finally, 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 an interest. My use of the Mt. Baker-Snoqualmie roadless areas, and my expectation that public lands will be managed for the preservation of native plants and animals and for the conservation of valuable ecosystem services, developed in reliance on the protections the 2001 rule established. An agency changing course must assess the reliance interests its prior policy created. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before any final action is taken. Sincerely, Autumn Maust Clinton, Washington