Comment Analysis · Docket FS-2025-0001

FS-2025-0001-442913

Opposes rescissionA2 moderateSubstance 13/24Owed an answerPosted September 17, 2026 On Regulations.gov

In short: The comment places on the record specific deficiencies in the agency's analysis regarding wildlife survival, wildfire ignition data (DEIS Table 21), and economic cost-benefit projections, while identifying specific roadless areas in Gifford Pinchot and Olympic National Forests and requesting the agency explain how rescission aligns with its own findings and prior legal history.

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.

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
- “Elk avoid areas near roads and select habitat away from them”
- “moose... are drawn to road corridors for road salt, which increases human-moose interactions and conflict”
- “increased contact and conflict that come with open roads in grizzly habitat can ultimately end in grizzly mortality”
- “none of them survive a landscape carved open by new roads”
Recreation Tourism Public Use
- “The solitude of hiking and camping as far off the beaten path as possible is healing”
- “bikepacking the Dark Divide to hiking, foraging, and watching wildlife”
- “recreation losses of at least $6.1 million a year”
- “The wild and rugged beauty is unmatched”
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 DEIS Table 21”
- “far higher fire density on roaded land than inside the affected roadless areas”
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”
- “expanding a road system already carrying a $6.9 billion maintenance backlog”
- “timber revenue to the Forest Service of $5.2 to $11.4 million a year against recreation losses”

What it names

National Forests: Gifford Pinchot National Forest Olympic National Forest
Roadless areas: Dark DivideDeer CreekSouth QuinaultTumwaterUpper Skokomish

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The solitude of hiking and camping as far off the beaten path as possible is healing. That is not a preference I can replicate elsewhere, and the places I have named here cannot be replicated at all once roads divide them. I am writing to oppose the rescission of the 2001 Roadless Area Conservation Rule and to ask that the agency respond to the specific concerns below. The Gifford Pinchot is one of the most special places in the Pacific Northwest because of the roadless rule. I can do almost all of my favorite things there, from bikepacking the Dark Divide to hiking, foraging, and watching wildlife. The wild and rugged beauty is unmatched, and there are not many places like this left in the USA. This is our natural and cultural legacy, and that is priceless. The Tumwater roadless area at 8,676 acres, the Deer Creek area at 882 acres, and the roughly 213,000 acres of inventoried roadless land in Gifford Pinchot National Forest form the landscape that makes all of this possible. Stumbling upon elk or moose, seeing bears, hearing unfamiliar bird calls: these are the experiences that define the place for me, and none of them survive a landscape carved open by new roads. The agency's own record shows what roads do to those animals. Elk avoid areas near roads and select habitat away from them, and the DEIS documents that elk survival rates rose during a road closure and fell again when the gates were removed. For moose, the DEIS notes they are drawn to road corridors for road salt, which increases human-moose interactions and conflict. And for bears, the agency's own draft environmental impact statement quotes the federal grizzly recovery plan: "the increased contact and conflict that come with open roads in grizzly habitat can ultimately end in grizzly mortality, and shooting, habituation and food reward all increase with the use of even secondary unpaved roads." If the agency proceeds with rescission, I ask it to explain how opening roadless habitat in Washington's 139 inventoried roadless areas, totaling 2,014,832 acres, is consistent with its own documented findings on roads and wildlife survival. 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." I ask that the agency explain why the proposal departs from that finding, and that it reconcile the rescission with the ignition data in its own DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic justification is equally unsettled. 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." The agency's own cost-benefit analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year, with a net present value ranging from -$92 million to +$199 million. That range does not establish a net benefit. The agency should explain on the record how a proposal whose own analysis cannot confirm positive returns justifies expanding a road system already carrying a $6.9 billion maintenance backlog. The proposal also argues that state-by-state approaches can substitute for a national rule. The agency's own record quotes its prior position: "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 should address what the Ninth Circuit found deficient the last time it substituted local decision-making for the national rule, and explain how this proposal avoids repeating those deficiencies. I have spent a decade in the Upper Skokomish, 9,311 acres in Olympic National Forest. I scattered the ashes of my golden retriever Soma there because it was that meaningful to both of us. The South Quinault roadless area, 11,081 acres in the same forest, belongs to the same landscape and the same kind of memory. These places deserve the protection the 2001 rule provides, and the agency has not shown on its own numbers that removing that protection serves the public. Sincerely, Makaela Kroin Olympia, WA