Comment Analysis · Docket FS-2025-0001

FS-2025-0001-346773

Opposes rescissionA3 weakSubstance 8/24Owed an answerPosted September 12, 2026 On Regulations.gov

In short: The comment places on the record specific scientific evidence regarding water supply dependencies and wildfire ignition densities near roads, along with personal observation of salmon in Silver Creek, Mt Baker-Snoqualmie National Forest, to argue against the rescission of the 2001 Roadless Area Conservation Rule.

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

A3 weak: Substantive, but easier to set aside.

Owed an answer on 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.
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.
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.
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
- “clear water will go away”
- “National forests supply drinking water to millions of people”
- “Roads are a major cause of water pollution”
- “vital for maintaining clean drinking water”
Forest Management Wildfire
- “peer-reviewed science shows the opposite”
- “wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads”
- “building roads into roadless areas is likely to result in more fires”
- “84% of all U.S. wildfires are human-caused”
Wildlife Habitat
- “salmon need streams like these to survive and breed”
- “degrade habitat quality”
- “put these species in jeopardy”
- “saw the salmon swimming upstream”
Recreation Tourism Public Use
- “As an outdoor enthusiast”
- “Nothing brings me more peace than to sit in nature”
- “Please keep the land as it is”
- “Don't take away the beauty this earth has created”

What it names

National Forests: Mt Baker-Snoqualmie National Forest
Roadless areas: Silver Creek

The comment

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

As an outdoor enthusiast, I respectfully direct the Department's attention to the fact that the proposed rescission of the 2001 Roadless Area Conservation Rule would shift the default management posture for 58 million acres of national forest from protection to potential development — a shift whose administrative justification, as presented, does not match its scale. Nothing brings me more peace than to sit in nature the way it was intended. Witnessing full grown trees and clear water will forever be priceless. If the roadless rule gets rescinded the clear water will go away. When I was in Silver Spring campground in Mt Baker-Snoqualmie National Forest, I saw the salmon swimming upstream and it was so beautiful. The salmon need streams like these to survive and breed. To put these species in jeopardy is to put our own use of these natural resources in jeopardy. Not just clean water for salmon but for us. Rescinding the Roadless Rule would open the Silver Creek, Mt Baker-Snoqualmie National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. National forests supply drinking water to millions of people across most of the United States. The U.S. National Forests are the headwaters of our great rivers and the largest source of municipal water supply in the nation. According to DellaSala (2011), national forests supply drinking water to at least 124 million people in more than 3,400 communities across 33 states—roughly a third of all national-forest runoff originates in inventoried roadless areas. Roads are a major cause of water pollution: erosion rates from logging roads have been documented as much as 850% higher than from undisturbed forest. Because the 2001 Roadless Rule protects these headwaters, it is vital for maintaining clean drinking water for communities across the country. Major U.S. cities including Los Angeles, Portland, Denver, and Atlanta receive a significant portion of their water supply from national forests. https://www.federalregister.gov/d/01-726/p-60 Regarding wildfire suppression: “although proponents of rolling back the Roadless Rule claim it is needed for wildfire management, the peer-reviewed science shows the opposite. A 2026 study in Fire Ecology by Aplet, Hartger & Dietz analyzed 32 years of wildfire data across all eight contiguous U.S. Forest Service regions and found wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads, compared to just 1.97 fires per 1,000 hectares in inventoried roadless areas—a fourfold difference. A separate national analysis (Balch et al., PNAS 2017) found that 84% of all U.S. wildfires are human-caused. Roads are the primary vector for human ignitions, so building roads into roadless areas is likely to result in more fires, not fewer” (Aplet et al., 2026). Rescinding the Roadless Rule will inevitably lead to more logging. Timber harvest, associated road construction, and vegetation removal directly alter roadless character and degrade habitat quality. https://www.federalregister.gov/d/01-726/p-62 Please keep the land as it is. Don’t take away the beauty this earth has created.