Comment Analysis · Docket FS-2025-0001

FS-2025-0001-408716

Opposes rescissionA2 moderateSubstance 13/24Owed an answerPosted September 15, 2026 On Regulations.gov

In short: The comment documents that the DEIS fails to adequately analyze the specific impacts of road construction on bull trout and Pacific Lamprey in the Granite Mountain IRA, citing scientific data on thermal limits and sediment generation to argue that deferring this analysis to project-level review is insufficient under NEPA.

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, 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.
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

Water Quality Quantity
- “Headwater Protection for Bull Trout and Cold-Water Fisheries”
- “shade streams and regulate water temperature”
- “degrade water quality and temperature conditions”
- “quantified sediment yield”
Wildlife Habitat
- “federally threatened species with designated critical habitat”
- “degrades habitat for Pacific Lamprey”
- “driving bull trout away from spawning and rearing habitat”
- “greatest risk to fish resources”
Recreation Tourism Public Use
- “outdoor enthusiast”
- “show my children what being in nature is truly about”
- “tallying how many animals and species they have seen”
- “ability for my children to enjoy these areas”
Legal Regulatory Framework
- “The DEIS cannot defer analysis of road construction impacts”
- “NEPA requires the agency to analyze the consequences”
- “Let the Roadless Rule stand”

What it names

National Forests: Okanogan National Forest
Roadless areas: Beaver CreekBuck CreekGranite Mountain

The comment

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

To Whom It May Concern at the U.S. Forest Service: For an outdoor enthusiast, "roadless" isn't a bureaucratic category - it's a description of what makes a place worth going to. The best part about these areas is that they are the only place I can truly show my children what being in nature is truly about. So they can appreciate it and teach others. My kids' favorite part of a trip is tallying how many animals and species they have seen. I fear on some trips this will be the last time they see them. The ability for my children to enjoy these areas with their children. Regarding the Granite Mountain in the Okanogan National Forest, Washington: Headwater Protection for Bull Trout and Cold-Water Fisheries - The Upper Beaver Creek headwaters and associated drainage network (Beaver Creek, Blue Buck Creek, North Fork Beaver Creek) originate in this high-elevation subalpine terrain, where snowmelt and groundwater maintain the cold, clear water conditions essential for bull trout (Salvelinus confluentus), a federally threatened species with designated critical habitat in this watershed. The intact riparian buffers and undisturbed streamside vegetation in this roadless area - particularly the subalpine fir and lodgepole pine forests - shade streams and regulate water temperature, preventing the thermal stress that would otherwise drive bull trout away from spawning and rearing habitat. Loss of this headwater protection would degrade water quality and temperature conditions throughout the downstream drainage network, directly threatening the species' survival in the region. Forest roads generate sediment from every constructed surface: the compacted road prism sheds runoff instead of absorbing it, cut slopes expose bare soil to erosion, fill slopes slump into drainages, and ditchlines concentrate and accelerate flow. In the Granite Mountain IRA, each stream crossing becomes a direct delivery point where this sediment enters the channel and degrades habitat for Pacific Lamprey (Entosphenus tridentatus). The DEIS cannot defer analysis of road construction impacts on Pacific Lamprey (Entosphenus tridentatus, G4) in the Granite Mountain IRA, Okanogan National Forest, to future project-level review. Rescission is the decision that enables road construction, and NEPA requires the agency to analyze the consequences of that enabling decision - including quantified sediment yield, modeled thermal impacts, and assessed flow regime changes - at the programmatic stage for a G4-ranked aquatic species. "For age-0 bull trout, the upper lethal temperature is 70 F (20.9 C), and optimal growth occurred at 56 F (13.2 C); feeding declined significantly above 61 F (16 C). As stream temperatures rise, dissolved oxygen content decreases. Salmon, trout and other cold water fish, and many aquatic invertebrates require cool and well-oxygenated water." - Washington Department of Fish and Wildlife, 2001 The DEIS supplies the mechanism the conclusion has to survive. Two sentences earlier, on the same page, it states: "Roads pose the greatest risk to fish resources on the Tongass, partly because they pose the largest risk of management-caused sediment input to streams." The DEIS cannot both identify road-caused sediment as the greatest risk to Tongass fish resources and rest a "minimal effects" conclusion on a set of protections from which it has deleted the prohibition on road construction in the highest-value salmon watersheds. Let the Roadless Rule stand.