Comment Analysis · Docket FS-2025-0001

FS-2025-0001-371593

Opposes rescissionA1 strongSubstance 14/24Owed an answerPosted September 12, 2026 On Regulations.gov

In short: The comment establishes that the proposed rescission of the Roadless Area Conservation Rule contradicts the agency's own findings on wildfire ignition rates, fails to demonstrate a net economic benefit given a $6.9 billion maintenance backlog, ignores the legal validity of the 2001 rule as affirmed by the Tenth Circuit, and lacks the procedural rigor of the original rulemaking, specifically regarding impacts on Colville National Forest wildlife and Pacific Northwest water intakes.

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, 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
- “Family outings to the Colville National Forest are how we spend time together”
- “watching wildlife and getting into nature”
- “South Huckleberry, Bangs, Thirteenmile, Cougar Mountain, Bald Snow, and Hoodoo are the kinds of roadless places that make those trips worth taking”
- “recreation losses of at least $6.1 million a year”
Forest Management Wildfire
- “Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires”
- “A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands”
- “reconcile the rescission with the ignition data in its own draft environmental impact statement”
- “Our roads are hardly maintained at all as it is. Adding more roads makes absolutely no sense at all”
Wildlife Habitat
- “Bear habitat in the Colville National Forest depends on limiting road access”
- “open roads in grizzly habitat increase contact and conflict and can ultimately end in grizzly mortality”
- “shooting, habituation, and food reward all rising with the use of even secondary unpaved roads”
- “The wildlife my family goes to the Colville to see is directly affected by that finding”
Water Quality Quantity
- “1,522 municipal water intakes sit in watersheds containing affected roadless areas”
- “Children should not have to bear the burden of what this will do, to the water”
- “to the water, to the wildlife, to the places that remain unroaded”

What it names

National Forests: Colville National Forest
Roadless areas: Bald SnowCougar MountainSouth Huckleberry
Law cited: 28 U.S.C. Section 1291

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Family outings to the Colville National Forest are how we spend time together, watching wildlife and getting into nature. South Huckleberry, Bangs, Thirteenmile, Cougar Mountain, Bald Snow, and Hoodoo are the kinds of roadless places that make those trips worth taking. I am writing to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001, and to ask the agency to answer the specific questions this record raises. Washington holds 139 inventoried roadless areas totaling 2,014,832 acres. The agency proposes to strip the rule protecting all of them. One reason given is wildfire and fuels management, yet the agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." That finding does not support rescission; it argues against it. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence in roadless areas, and reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. Our roads are hardly maintained at all as it is. Adding more roads makes absolutely no sense at all. The agency's record already documents why: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The projected timber revenue to the Forest Service runs $5.2 to $11.4 million a year, set against recreation losses of at least $6.1 million a year and a net present value ranging from -$92 million to +$199 million. The agency cannot establish a net benefit from its own cost-benefit analysis, and the road system it already operates carries a $6.9 billion maintenance backlog against a road budget of roughly $73 million a year. The agency must reconcile the proposal with these numbers and explain how expanding a road network the agency cannot maintain serves the public interest. The agency argues that state-specific approaches can substitute for a national rule, but its own record reflects a different history: "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The agency's own earlier findings acknowledged that local decision-making can incrementally erode nationally significant roadless values. The Ninth Circuit has already reviewed what happens when a national rule is replaced with a state-by-state approach. I ask that the agency explain how this proposal avoids the deficiencies identified in that litigation. The agency also suggests the 2001 rule may have exceeded statutory authority, but a court has already ruled directly on that question. The Tenth Circuit's holding was: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." That court found the rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. The agency must state on the record what legal basis supports a contrary position now. Bear habitat in the Colville National Forest depends on limiting road access. The agency's own record, drawing on the federal grizzly recovery plan, documents that open roads in grizzly habitat increase contact and conflict and can ultimately end in grizzly mortality, with shooting, habituation, and food reward all rising with the use of even secondary unpaved roads. The wildlife my family goes to the Colville to see is directly affected by that finding. The agency must address it directly. Across the Pacific Northwest region, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. Children should not have to bear the burden of what this will do, to the water, to the wildlife, to the places that remain unroaded. The rule was written after more than 600 public meetings and 1.6 million comments. No comparable process has been held to undo it. The agency should say why that asymmetry is acceptable. Sincerely, Brenda L. Williams Farmington, Wa