Comment Analysis · Docket FS-2025-0001

FS-2025-0001-357641

Opposes rescissionA3 weakSubstance 11/24Owed an answerPosted September 12, 2026 On Regulations.gov

In short: The comment places on the record specific economic data regarding Washington's outdoor recreation industry and the Forest Service's road maintenance backlog, along with the commenter's personal reliance on specific roadless areas in the Gifford Pinchot and Okanogan-Wenatchee National Forests, to argue that rescinding the 2001 Roadless Rule would cause economic harm and fail to address actual wildfire mitigation needs.

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

Recreation Tourism Public Use
- “outdoor enthusiast who spends significant time”
- “quiet, roadless country you can't manufacture back”
- “hikers, climbers, hunters, and anglers”
- “degrade the very backcountry character that draws that spending”
Economic Impact Fiscal
- “threatens real economic harm to the towns, cities, and state economies”
- “Outdoor recreation contributes roughly $26.5 billion annually”
- “trading a short-term timber yield for a long-term hit to tourism-dependent local economies”
- “saves taxpayers money: the Forest Service already carries a nearly $6 billion road maintenance backlog”
Environmental Protection Biodiversity
- “protecting one of the last stretches of old-growth forest”
- “buffers the wilderness from the industrial development”
- “opening these roadless areas to logging and road construction”
- “pristine backcountry to new roads and logging”
Forest Management Wildfire
- “inventoried roadless areas... accounting for only a small share of wildfire starts”
- “roads themselves are one of the biggest drivers of human-caused ignitions”
- “doesn't address the workforce and funding shortfalls”
- “opens pristine backcountry to new roads and logging under the banner of fire policy”

What it names

National Forests: Gifford Pinchot National Forest Wenatchee National Forest
Roadless areas: Dark Divide

The comment

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

I'm writing as an outdoor enthusiast who spends significant time in the Gifford Pinchot National Forest, Goat Rocks Wilderness, and the Okanogan-Wenatchee National Forest around the Alpine Lakes Wilderness, to strongly oppose the USDA's proposal to rescind the 2001 Roadless Rule. These landscapes matter to me personally. In the Gifford Pinchot, the inventoried roadless areas — including the Dark Divide, the largest roadless area in the forest — form the connective backcountry between Mt. Adams and the Goat Rocks Wilderness, protecting one of the last stretches of old-growth forest left in southwest Washington. More than 60,000 acres there are at risk under this proposal. In the Okanogan-Wenatchee, the Forest Service has inventoried roughly 184,000 acres of roadless land in its portion of the Alpine Lakes alone, including the Icicle River corridor near Leavenworth — country I hike and climb in regularly, and which buffers the wilderness from the industrial development this rule change would allow. Beyond my personal stake, this proposal threatens real economic harm to the towns, cities, and state economies that depend on these forests. Outdoor recreation contributes roughly $26.5 billion annually to Washington's economy and supports around 264,000 jobs statewide, much of it concentrated in small gateway communities like Leavenworth, Packwood, and Randle that rely on hikers, climbers, hunters, and anglers passing through. Statewide, visitors spend nearly $1 billion a year in communities surrounding the national forests this rule protects. Opening these roadless areas to logging and road construction would degrade the very backcountry character that draws that spending in the first place — trading a short-term timber yield for a long-term hit to tourism-dependent local economies. It's also worth noting the rule itself saves taxpayers money: the Forest Service already carries a nearly $6 billion road maintenance backlog, and building new roads into remote, often economically marginal terrain would only add to that burden. I understand the agency frames this as a wildfire and forest-management issue. But inventoried roadless areas make up roughly 28% of Forest Service land while accounting for only a small share of wildfire starts — and roads themselves are one of the biggest drivers of human-caused ignitions. Removing this rule doesn't address the workforce and funding shortfalls that have actually limited the Forest Service's fire mitigation work; it just opens pristine backcountry to new roads and logging under the banner of fire policy, at a real economic cost to the communities that depend on that backcountry staying intact. I've built years of hiking, backpacking, and climbing trips around the wild character of these forests — quiet, roadless country you can't manufacture back once it's fragmented, and one of the state's genuine economic assets. I ask the USDA to withdraw this proposal and keep the Roadless Rule fully intact. Thank you for considering my comment.