Comment Analysis · Docket FS-2025-0001

FS-2025-0001-334705

Opposes rescissionA1 strongSubstance 16/24Owed an answerPosted September 8, 2026 On Regulations.gov

In short: The comment establishes that the DEIS lacks scientific integrity by failing to reference the T2 conservation status and documented population decline severity for the Mount Rainier White-tailed Ptarmigan in the Sawtooth area, and that the agency's reduction of 99% public opposition to a bare percentage without substantive engagement of specific content categories (water quality, carbon storage, invasive species) violates the requirement for reasoned consideration under Vermont Yankee and the APA.

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

  • Recreation Tourism Public Use
    • “recreates in multiple roadless areas”
    • “peaceful, serene environment that would be destroyed”
    • “retreat and tend to my mental and physical health”
    • “incredible wild, beautiful spaces”
  • Wildlife Habitat
    • “Mount Rainier White-tailed Ptarmigan”
    • “Roads fragment intact habitat”
    • “direct loss of habitat”
    • “indirect loss of habitat (by the fragmentation of an ecosystem)”
  • Governance Policy Process
    • “Failure to Substantively Respond to Content of Majority-Opposition Comments”
    • “violates the requirement that agencies give reasoned consideration to public comment”
    • “arbitrary and capricious under APA”
    • “request a substantive, topic-by-topic response”
  • Water Quality Quantity
    • “reroute surface and subsurface water flow”
    • “pollution of off-site waters”
    • “sediment delivery that is long-lasting and cumulative”

What it names

National Forests
Okanogan National Forest
Roadless areas
Sawtooth
Law cited
435 U.S. 519

The comment

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

To the Department of Agriculture and the Forest Service: I am writing to express my deep concern for the proposed rescinding of the Roadless Rule. As someone who lives near and recreates in multiple roadless areas I can’t express how strongly I feel about the negative impacts this will have. One area in particular is the Sawtooth area, which connects two valleys that hold great importance to me - the Chelan and the Methow. This is one of the main areas I can easily access by foot to quickly escape into nature. The lack of roads in this area provides a peaceful, serene environment that would be destroyed if roads were allowed here. If roads were to come into this area I would lose my most sacred spaces in which I am able to retreat and tend to my mental and physical health. Regarding the Sawtooth in the Okanogan National Forest, Washington: Slight or 1-10% pop. decline severity and Small (1-10%) scope characterize the impact of 6.1 - Recreational activities on Mount Rainier White-tailed Ptarmigan (Lagopus leucura rainierensis, T2) in the Sawtooth Inventoried Roadless Area, Okanogan National Forest — losses that the current Roadless Rule helps constrain. Roads fragment intact habitat through cut-and-fill earthwork, compact soils, reroute surface and subsurface water flow, and create impervious surfaces — each mechanism amplifying the effects of 6.1 - Recreational activities on Mount Rainier White-tailed Ptarmigan. Analysis of 6.1 - Recreational activities effects on Mount Rainier White-tailed Ptarmigan (Lagopus leucura rainierensis) in Sawtooth must reference the species' T2 conservation status and the documented Slight or 1-10% pop. decline severity. The DEIS lacks scientific integrity without this baseline data. "On steep terrain, 21% of trees were damaged by excavators and 33% of trees were damaged by bulldozers during forest road construction, and on very steep terrain, 27% of trees were damaged by excavators and 44% of trees were damaged by bulldozers during forest road construction. Inadequately constructed forest roads can cause severe environmental impacts including road surface erosion and sediment yield, pollution of off-site waters, slope failures and mass movement, direct loss of habitat (by the conversion of the original land cover into an artificial surface) and indirect loss of habitat (by the fragmentation of an ecosystem into smaller and more isolated patches)." — Iranian Journal of Environmental Health Science & Engineering (PMC), 2013 Failure to Substantively Respond to Content of Majority-Opposition Comments The Notice of Intent section reduces overwhelming public opposition to a bare percentage, stating that "approximately 99 percent were generally opposed to the proposed rule recission, while approximately 1 percent were generally in support," without any accompanying discussion of what those commenters actually said. No substantive response section addressing the content categories raised — water quality, carbon storage, invasive species spread — appears associated with this passage. Independent research the agency should engage directly documents that roads cause "increased mortality from road construction," "spread of exotic species," and sediment delivery that is "long-lasting and cumulative and cannot be effectively mitigated" (Trombulak & Frissell 2000). Did the agency consider comments raising these documented mechanisms, and if so, where in the record is that consideration explained? Reducing majority opposition to a percentage without engaging its substance violates the requirement that agencies give reasoned consideration to public comment under Vermont Yankee Nuclear Power Corp. v. NRDC, 435 U.S. 519 (1978), and is arbitrary and capricious under APA 5 U.S.C. § 706(2)(A). I request a substantive, topic-by-topic response to the content of majority-opposition comments before this rescission is finalized. People travel from all over the world to visit our country because of the incredible wild, beautiful spaces we are lucky to live among. We have protected these places for great reason and the vast majority of people in this country do not want to see this change, myself included. Twenty-plus years of protection shouldn't end here. Keep the Rule. Sincerely, CommentID: RLC-20260908-92QQJG

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