Comment Analysis · Docket FS-2025-0001

FS-2025-0001-416195

Opposes rescissionA2 moderateSubstance 14/24Owed an answerPosted September 16, 2026 On Regulations.gov

In short: The comment documents specific deficiencies in the agency's analysis regarding the lack of projections for big game population effects and habitat fragmentation across the 40.1 million acres of affected environment, while citing specific local areas in Washington State and requesting reconciliation of the proposal with the agency's own data on wildfire ignition, sediment production, and economic costs.

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

Wildlife Habitat
- “prime habitat for these animals”
- “reduce wildlife habitat, affect migration corridors”
- “elk survival rates increased during a road closure”
- “habitat fragmentation reduces biodiversity”
Water Quality Quantity
- “oppose any action that would reduce water quality”
- “1,522 municipal water intakes sit in watersheds”
- “roads and their facilities can produce up to 90 percent of the sediment”
- “tributaries flow from wilderness areas”
Recreation Tourism Public Use
- “wild places I work, hunt, and hike in”
- “value it for its remoteness and beauty”
- “Public land should be managed for public use”
- “Recreation, hunting, clean water, and habitat health should be the priority”
Forest Management Wildfire
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “More roads would just provide another vector for a large fire to start”
- “Little Giant Fire burned over 150,000 acres”
- “Exemptions already exist for wildland firefighters”

What it names

National Forests: Gifford Pinchot National Forest Wenatchee National Forest

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The wild places I work, hunt, and hike in are worth fighting for, and the proposed rescission of the 2001 Roadless Area Conservation Rule would damage them in ways that cannot be undone. I'm a conservation professional based in Washington State. I lead a crew that performs trail work, riparian restoration, forest thinning, and wildfire fuels mitigation across the state. I work to improve these areas for wildlife and people. This change would act against that goal. I'm also an avid waterfowl, deer, and elk hunter. Many of the areas this rescission would affect are prime habitat for these animals, and areas where I hunt. I also go birdwatching throughout Washington State, including the Okanogan-Wenatchee National Forest and the Gifford Pinchot National Forest, and many tracts of roadless areas nearby. Birds rely on healthy forests, clean water, and areas with little human interference. Allowing roads and extraction into these places would reduce wildlife habitat, affect migration corridors, and put pressure on already stressed populations. Part of the appeal of hunting is the challenge of getting deep into natural habitat. Roads reduce that challenge and make hunting less rewarding, not to mention increase pressure in areas that are currently difficult to access. I hunt turkey and elk in the Teanaway, which covers 72,849 acres in the Wenatchee National Forest. Adding roads there would push these animals out and reduce hunting opportunities. I hike and hunt in the 11,155-acre Manastash area as well, and I do not want more roads there disrupting wildlife and increasing wildfire risk. I build and maintain trails in the Alpine Lakes area, a 57,104-acre roadless area in the Wenatchee National Forest, and the hikers I met working there value it for its remoteness and beauty. The Goat Rocks, at 6,108 acres, is one of my favorite areas in Washington, with panoramic views of the Cascade Range and little evidence of human construction. Reducing protections would make it less beautiful and less special. I get water from the Yakima River, whose tributaries flow from wilderness areas, roadless areas, and national forests. I oppose any action that would reduce water quality for my area through the creation of new roads for mining or timber harvest. Across the Pacific Northwest region, including Washington, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. The agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale. I ask that the agency explain what specific protections will replace the rule's watershed safeguards for the communities that depend on those intakes. On wildfire, 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." This summer has been one of the worst fire seasons in Washington. The Little Giant Fire burned over 150,000 acres, and many fires are started from roadways by humans. Exemptions already exist for wildland firefighters to access roadless areas when necessary. More roads would just provide another vector for a large fire to start. I ask that the agency explain why the proposal departs from its own prior findings and reconcile the rescission with the ignition data in its own DEIS. On economics, the agency's own record states: "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." I ask that the agency reconcile this with its own cost-benefit analysis and explain how expanding a road system already carrying a $6.9 billion maintenance backlog serves the public interest. The agency's own DEIS cites the finding that "elk survival rates increased during a road closure and decreased when the gates were removed (Cole 1997), and that elk avoid roads and select unroaded habitat." No population-level effect on big game or hunter opportunity is projected anywhere in the document. The agency must project those effects before proceeding. Finally, the DEIS cites the finding that "habitat fragmentation reduces biodiversity by 13 to 75 percent." That number appears in the record, but no projection across the 40.1 million acres of potentially affected environment follows. The agency should apply that cited range to the full scope of the affected landscape. Public land should be managed for public use, not extractive economic interests. Recreation, hunting, clean water, and habitat health should be the priority. I urge the agency to withdraw this proposal. Sincerely, Sam McClintic Ellensburg, Washington