Comment Analysis · Docket FS-2025-0001

FS-2025-0001-375448

Opposes rescissionA1 strongSubstance 15/24Owed an answerPosted September 13, 2026 On Regulations.gov

In short: The comment establishes that the rescission of the Roadless Area Conservation Rule would negatively impact biodiversity, wildlife habitat, and recreation access in Washington's national forests, and that the agency must address these impacts given its own analysis.

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, Evidence, 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

Wildlife Habitat
- “look for bears, marmots, wolverines, fishers, martens, and pika”
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
- “wolverine avoid roads used by winter machines”
- “grizzly bear "have suffered habitat loss and the extirpation or fragmentation of their populations"”
Recreation Tourism Public Use
- “scenery and the challenge of being away from civilization”
- “continuously amazed the beauty and at all the nooks and crannies still left to explore”
- “recreation losses of at least $6.1 million a year”
- “outfitters, guides and tour operators as affected”
Forest Management Wildfire
- “Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “DEIS Table 21 reports far higher fire density on roaded land”
- “reconcile the rescission with the ignition data in its own environmental analysis”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “net present value ranging from -$92 million to +$199 million”
- “road system already carries a $6.9 billion maintenance backlog”
- “expanding a deficit-carrying road system is justified by numbers this uncertain”

What it names

National Forests: Gifford Pinchot National Forest Wenatchee National Forest
Law cited: 36 C.F.R. Section 294.12

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledge

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I am filing this comment to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001). The scenery and the challenge of being away from civilization are what pull me into the backcountry of Washington, the eastern Sierra, and Utah, to name a few places. Since I moved to Washington in 2009 I have been visiting the Okanogan Wenatchee National Forest, and I am continuously amazed the beauty and at all the nooks and crannies still left to explore. It would be a shame to lose them to mining and logging interests. The same holds for the inventoried roadless areas of the Mt. Baker-Snoqualmie National Forest, Gifford Pinchot National Forest, and Olympic National Forests, including Glacier Peak, Noisy-Diobsudand Alpine Lakes, Stephen Mather, Dan Evans, Hank Jackson, Pasayten, and Mt Baker Wildernesses. Washington holds 139 inventoried roadless areas totaling 2,014,832 acres. These are the landscapes where I look for bears, marmots, wolverines, fishers, martens, and pika. The agency's own record gives me reason for concern about all of them. The DEIS cites findings that habitat fragmentation reduces biodiversity by 13 to 75 percent, that marten disappear when forest cover thins, and that wolverine avoid roads used by winter machines. On wider-ranging mammals, the DEIS describes how species like the grizzly bear "have suffered habitat loss and the extirpation or fragmentation of their populations." The increased contact and conflict that come with open roads in grizzly habitat can, as quoted in the DEIS, ultimately end in grizzly mortality. I ask that the agency address on the record how rescission of the rule protects the populations of wide-ranging and road-sensitive species in Washington's affected roadless areas and beyond, given its own analysis. Re: birds, the record speaks clearly enough. The DEIS cites findings that bird richness declines with road presence in forested habitat, and road-noise cuts bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. What does the agency propose to address those findings if it opens these areas? The proposal justifies rescission partly on wildfire and fuels management grounds. 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." DEIS Table 21 reports far higher fire density on roaded land than inside the affected roadless areas. The agency must explain why the proposal departs from these findings and reconcile the rescission with the ignition data in its own environmental analysis. The economic case for rescission is, by the agency's own accounting, thin. The DEIS records that "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 agency's Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service, 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 road system already carries a $6.9 billion maintenance backlog. The agency must explain on the record how expanding a deficit-carrying road system is justified by numbers this uncertain. On administrative burden: the rule the agency proposes to rescind already contains its own release valves. It "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." Exceptions also exist for existing mineral leases and community wildfire protection. The agency has not identified which specific burdens fall outside these provisions. It should do so, with numbers, before proceeding. Finally, the proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. That certification is reached by spreading estimated losses across every small firm in the sector nationally rather than examining the guides and outfitters actually holding permits in affected areas, and the analysis concedes some firms may lose these receipts. The agency should withdraw the certification and conduct a proper assessment of the small entities operating in the places this rule would affect, not a national average that obscures the local harm. Sincerely, Megan Snyder Seattle, WA