Comment Analysis · Docket FS-2025-0001

FS-2025-0001-358956

Opposes rescissionA3 weakSubstance 9/24Owed an answerPosted September 12, 2026 On Regulations.gov

In short: The comment documents specific local impacts in the Mt. Baker-Snoqualmie National Forest, including the diminished Nisqually glacier and reduced streamflow in the Nooksack system, and cites Talty et al. (2020) to argue that rescinding the Roadless Rule would threaten cold-water habitats for threatened salmonids and undermine the integrity of the protected-area system.

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
    • “Headwater Cold-Water Refuge for Threatened Salmonids”
    • “glacial meltwater and high elevation maintain the cold water temperatures”
    • “intact forest canopy and undisturbed riparian zones preserve the remaining cold-water pulse”
    • “58% of the watersheds intersecting National Forest System lands supply drinking water”
  • Wildlife Habitat
    • “essential for bull trout (*Salvelinus confluentus*, federally threatened)”
    • “Dolly Varden (*Salvelinus malma*, proposed threatened)”
    • “critical connectivity for climate-driven range shifts”
    • “96% of IRAs are wilder than the median of the contiguous U.S.”
  • Environmental Protection Biodiversity
    • “IRAs would expand the U.S. protected-area system by 27%”
    • “proven pipeline for permanent congressional protection”
    • “disproportionately buffering its largest cores”
    • “increase well-protected drinking-water watersheds by 60%”
  • Governance Policy Process
    • “making a radical change should include a serious public process”
    • “should be sure to include the public”
    • “USFS's disclosures on roads and fire undermines the argument”
    • “vulnerable to degazettement”

What it names

National Forests
Mt Baker-Snoqualmie National Forest
Roadless areas
Middle ForkMt. Baker West
Works cited
10.1111/csp2.288

The comment

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

Dear Chief Tom Schultz, My husband's grandfather was a guide on Mt. Rainier, and our extended family visits the areas he loved every summer. We camp at White River and Ohanapecosh, and walk his favorite hikes in rememberance of him. We've encountered many bears and marmots, and we've noted the change in the alpine meadows flowers. The Nisqually glacier is drastically diminished from what it was 30 years ago. I live near Mount Baker-Snoqualmie Forest in Whatcom County, Washington. Rescinding the Roadless Rule would open the Mt. Baker West, 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. Headwater Cold-Water Refuge for Threatened Salmonids — The Upper Middle Fork Nooksack River and its tributaries (Clearwater Creek, Rocky Creek, Ridley Creek, and others) originate in Mt. Baker West's subalpine terrain, where glacial meltwater and high elevation maintain the cold water temperatures essential for bull trout (*Salvelinus confluentus*, federally threatened) and Dolly Varden (*Salvelinus malma*, proposed threatened under similarity of appearance). The Nooksack system currently experiences 27% lower August streamflow than natural conditions due to historical timber harvesting and glacial retreat. This roadless area's intact forest canopy and undisturbed riparian zones preserve the remaining cold-water pulse that these species depend on for spawning and rearing—a function that becomes increasingly critical as climate-driven warming reduces glacial contribution to late-summer flows. “Comprehensive assessment of the conservation value of all 240,000 km² of Inventoried Roadless Areas. The study finds IRAs would expand the U.S. protected-area system by 27% while disproportionately buffering its largest cores: adjacent IRAs add +29% to Greater Yellowstone, +38% to Central Idaho, +32% to the Bob Marshall, and +31% to the North Cascades. 96% of IRAs are wilder than the median of the contiguous U.S.; 93% lie within 10 km of an existing protected area, providing critical connectivity for climate-driven range shifts. 58% of the watersheds intersecting National Forest System lands supply drinking water to over 48 million people, and adding IRAs to the protected network would increase well-protected drinking-water watersheds by 60%. 74% of all Forest Service wilderness designated since 2000 was first an IRA — the rule is the proven pipeline for permanent congressional protection. The authors warn that because IRAs are an administrative designation, they remain vulnerable to degazettement. — Talty et al., 2020 (https://doi.org/10.1111/csp2.288)” These are public lands and making a radical change should include a serious public process should be sure to include the public. USFS's disclosures on roads and fire undermines the argument that building roads will protect forests. Very truly yours, CommentID: RLC-20260910-N4ESJF

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