Comment Analysis · Docket FS-2025-0001

FS-2025-0001-348737

Opposes rescissionA2 moderateSubstance 8/24Owed an answerPosted September 12, 2026 On Regulations.gov

In short: The comment establishes that the DEIS fails to meet NEPA's 'hard look' standard by lacking site-specific analysis of invasive species impacts on Whitebark Pine in the Mt. Baker Noisy - Diobsud IRA, and documents the specific severity and scope of these impacts as well as the threat of stream fragmentation from road construction.

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.

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

  • Environmental Protection Biodiversity
    • “Whitebark Pine (Pinus albicaulis, G3)”
    • “Invasive non-native/alien species/diseases”
    • “old growth forest”
    • “see wildlife there”
  • Water Quality Quantity
    • “Stream fragmentation is a leading threat to freshwater fish diversity”
    • “impassable culverts at road–stream crossings”
    • “chronic sediment inputs”
    • “destabilizes slopes”
  • Recreation Tourism Public Use
    • “outdoor enthusiast”
    • “we camp and hike in this region”
    • “enjoy the Baker Lake trail”
    • “lose the oportunity to hike”
  • Legal Regulatory Framework
    • “NEPA requires the agency to take a hard look”
    • “The DEIS fails this standard”
    • “specific regulatory prohibition”
    • “rescission would remove that prohibition”

What it names

National Forests
Mt Baker-Snoqualmie National Forest
Roadless areas
Mt. Baker Noisy - Diobsud

The comment

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

Dear Chief Tom Schultz, The sustained practice of traveling through roadless national forest has shown me, as an outdoor enthusiast, that what the 2001 Rule preserves is not preserved by default — it is preserved because the Rule creates a specific regulatory prohibition, and rescission would remove that prohibition across approximately 58 million acres. we camp and hike in this region and enjoy the Baker Lake trail through old growth forest, so quiet, and often see wildlife there. It is a treasure and would be ruined with a road. With a road and logging we would lose the oportunity to hike in the wonderful old growth forests. Regarding the Mt. Baker Noisy - Diobsud in the Mt Baker-Snoqualmie National Forest, Washington: Serious - moderate severity and Large (31-70%) scope characterize the impact of 8.1 - Invasive non-native/alien species/diseases on Whitebark Pine (Pinus albicaulis, G3) in the Mt. Baker Noisy - Diobsud Inventoried Roadless Area, Mt Baker-Snoqualmie National Forest — losses that the current Roadless Rule helps constrain. The physical footprint of road construction — grading, drainage installation, stream crossings — destabilizes slopes and generates chronic sediment inputs that intensify 8.1 - Invasive non-native/alien species/diseases in the Mt. Baker Noisy - Diobsud IRA. NEPA requires the agency to take a hard look at the effects of rescission on Whitebark Pine (Pinus albicaulis) in the Mt. Baker Noisy - Diobsud IRA. The DEIS fails this standard without site-specific analysis of 8.1 - Invasive non-native/alien species/diseases at the severity and scope documented by NatureServe. "Stream fragmentation is a leading threat to freshwater fish diversity and is often caused by the installation of impassable culverts at road–stream crossings. In the United States alone, millions of culverts contribute to this fragmentation. Emerging research suggests that smaller barriers, such as culverts, can have cumulative effects on riverine fragmentation that are comparable to those of large dams." — River Research and Applications (Wiley), 2026 There's a reason this rule has lasted this long. I'm asking the Department to respect that reason and keep it in place. With respect, CommentID: RLC-20260912-DIUWWQ

Keep learning. Keep speaking up.The Roadless Rule depends on public engagement. Share what you've learned.

© 2026 roadless.org - Defending America's Last Wild Forests

Privacy Policy|Questions or concerns? noroads@roadless.org|Follow us: @defendroadless