Comment Analysis · Docket FS-2025-0001

FS-2025-0001-297609

Opposes rescissionA1 strongSubstance 15/24Owed an answerPosted September 1, 2026 On Regulations.gov

In short: The comment establishes that the Draft EIS fails to provide site-specific impact analysis for the Mt. Baker North IRA as required by NEPA and 40 CFR 1502, and contains an unreconciled internal contradiction regarding wildfire ignition densities that violates the Administrative Procedure Act.

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, 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

Wildlife Habitat
- “set steelhead recovery back many many years”
- “specific impacts to watersheds, wildlife habitat, and ecological integrity”
- “distinct species assemblages”
Legal Regulatory Framework
- “NEPA does not permit substituting generic, landscape-scale analysis for site-specific impact evaluation”
- “A programmatic EIS covering 2,332 areas does not meet NEPA's requirement”
- “internal contradiction agencies must resolve under Motor Vehicle Manufacturers Association v. State Farm”
Water Quality Quantity
- “watershed configurations”
- “specific impacts of road construction on the particular watersheds”
- “swam all over the ocean, and found its way back to this little river”
Forest Management Wildfire
- “The Draft EIS never reconciles its own comparative fire data with its road-access rationale”
- “whether more roads will instead push ignition density in currently roadless areas toward the higher rate”
- “IRA ignition density at 12 fires per million acres per year”

What it names

National Forests: Mt Baker-Snoqualmie National Forest
Roadless areas: Little RiverMt. Baker North
Law cited: 145 S. Ct. 1497 284 F.3d 1062 40 CFR 1502 463 U.S. 29

The comment

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

To the U.S. Forest Service: As a biologist with a Master's degree in biology, I'm trained to distinguish between correlation and causation. The Department's logic here skips that step entirely. I have had a life long obsession with steelhead, a Rainbow Trout that goes out to the ocean then comes back to freshwater to spawn. This is what brought my family and I to Washington state. With so many threats to this already ESA listed species, the recinding the roadless rule would set steelhead recovery back many many years. If a single memory can stand for the whole of that attachment, it is this one. My first steelhead I caught in the Hoh River rainforest was one of the most special moments of my life. As a grown man, I cannot remember the last time my knees shook from so much adrenaline, excitement, and awe of this fish that had left freshwater, swam all over the ocean, and found its way back to this little river. I cannot express in words how much these fish mean to me from a recreational, scientific, and ecological perspective. The standing connection and the specific experience above together illustrate what the Rule has made possible over twenty-five years of operation. Regarding the Mt. Baker North in the Mt Baker-Snoqualmie National Forest, Washington: The Mt. Baker North IRA (16,873 acres) in Mt Baker-Snoqualmie National Forest possesses unique ecological characteristics — including distinct species assemblages, watershed configurations, and ecosystem composition — that a programmatic analysis covering 2,332 roadless areas cannot adequately evaluate. A programmatic EIS cannot evaluate the specific impacts of road construction on the particular watersheds, wildlife corridors, and ecological systems within the Mt. Baker North IRA (16,873 acres), Mt Baker-Snoqualmie National Forest. NEPA does not permit substituting generic, landscape-scale analysis for site-specific impact evaluation. The DEIS must include individualized analysis of the Mt. Baker North IRA (16,873 acres), Mt Baker-Snoqualmie National Forest, addressing site-specific impacts to watersheds, wildlife habitat, and ecological integrity. A programmatic EIS covering 2,332 areas does not meet NEPA's requirement under 40 CFR 1502 for analysis commensurate with the significance of the action. "Inventoried roadless areas considered in this rule constitute roughly one-third of all National Forest System lands, or approximately 58.5 million acres. Of the 58.5 million acres of inventoried roadless areas considered in the FEIS, approximately 34.3 million acres have prescriptions that allow road construction and reconstruction. The remaining 24.2 million acres are currently allocated to management prescriptions that prohibit road construction; however, protections in these existing plans may change after future forest plan amendments or revisions. Over the past 20 years, roads have been constructed in an estimated 2.8 million of those 34.3 million acres of inventoried roadless areas." — USDA Forest Service The Draft EIS never reconciles its own comparative fire data with its road-access rationale for rescission. On the one hand, the document states that "the number, frequency, and density of wildfire ignitions are lower in designated wilderness and potentially affected IRAs compared to other NFS lands," and its Wildfire Occurrence discussion reports IRA ignition density at "12 fires per million acres per year," compared to "42 fires per million acres per year" on other NFS lands—roughly 3.5 times higher. Yet elsewhere the DEIS suggests increased road access under Alternatives 2 and 3 will aid fire management, without addressing whether more roads will instead push ignition density in currently roadless areas toward the higher rate already observed on roaded lands. This is precisely the kind of internal contradiction agencies must resolve under Motor Vehicle Manufacturers Association v. State Farm Mutual Automobile Insurance Co., 463 U.S. 29, 43 (1983); Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002); and Seven County Infrastructure Coalition v. Eagle County (2025), consistent with APA 5 U.S.C. § 706(2)(A). I request a dedicated section reconciling these figures before finalization. The Department is urged to resolve this proceeding in favor of retention, not rescission. Yours truly, Garrett Rowles CommentID: RLC-20260901-ZYCHBW