Comment Analysis · Docket FS-2025-0001

FS-2025-0001-448506

Opposes rescissionA0 noneSubstance 8/24Posted September 21, 2026 On Regulations.gov

In short: The comment documents specific recreational, ecological, and economic values in the Mt. Baker-Snoqualamie and Chelan National Forests, including the fiscal impact of recreation versus timber, to argue that the Roadless Rule should be preserved.

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

A0 none: Counted, not answered.

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.
Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
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.
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.

Topics

Environmental Protection Biodiversity
- “irreparable harm to biodiversity”
- “rich with biodiversity”
- “save old growth forests as a matter of national defense”
- “keep our few remaining roadless areas protected”
Recreation Tourism Public Use
- “outdoor recreation in Mt. Baker-Snoqualamie NF”
- “WA's roadless forests are a recreation hotspot”
- “immersed in these spaces”
- “climb our world-class alpine terrain”
Water Quality Quantity
- “largest single source of sediment pollution in national forest streams”
- “headwater of Seattle's drinking supply”
- “I can drink the melt water”
- “industrial pollution from timber and mining”
Economic Impact Fiscal
- “magnitudes more fiscally impactful than the proposed timber and mining extraction”
- “$13.5b/year or 45x vs. $300m/year in timber sales inventory”
- “defend public land over short-term profit”
- “help slow industrialization”

What it names

National Forests: Allegheny National Forest
Roadless areas: Heather LakeLiberty BellMt. Baker North

Attachments

2 files. Counts as 1 — Counts as one: The attachments enclose no one else's submissions; the comment counts as one.

Own letter
Own letter

The comment

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

I'm a Washingtonian and passionate outdoorsman. I am a climber, mountaineer, hiker, & forager. I urge you to keep the Roadless Rule in place, defend public land over short-term profit, and pursue other forest management and fire-mitigation tactics. Per Access Fund, "The USFS asserts that rescinding the Roadless Rule is necessary to improve forest health and reduce wildfire risk, but it has not demonstrated that the Rule is a significant obstacle to effective fire or forest management." The Trump Administration is escalating development of public land and this is an example of that. Think downstream: once wild spaces are developed, it's done. Industry brings pollution & spreads invasive species; roads and logging destabilize the forest and are "the largest single source of sediment pollution in national forest streams" per Sierra Club; they do irreparable harm to biodiversity. We need to keep our few remaining roadless areas protected for the sake of our future generations. Per Sierra Club, outdoor recreation in Mt. Baker-Snoqualamie NF (MBSNF) is magnitudes more fiscally impactful than the proposed timber and mining extraction - $13.5b/year or 45x vs. $300m/year in timber sales inventory, and at risk if the roadless rule is rescinded. My home woods are MBSNF, one of the most intact wild spaces in the lower-48 states spanning the I-90 cooridor north up to the border with Canada, inclusive of many areas impacted by the proposal. MBSNF has brilliant stands of mature and old growth temperate rain forest, rich with biodiversity. Re: The USDoD's Project BioShield, mycologist Paul Stamets said, "We should save old growth forests as a matter of national defense," as they have irreplaceable biodiversity; these do not come back with tree farms and secondary timber stands. Much of the Cascades old growth has been logged; the rule has helped keep it unprofitable for the timber industry to log what remains. To create roads in these spaces changes that. Eg, Heather Lake, impacted by the proposal. Heather is an accessible alpine lake with stands of old growth, a gateway to Cascades hiking from Seattle. There is a palpable difference between the health of lower, secondary growth trail and upper old growth. Lower has huge cedar stumps, deep erosion, & lacks ground cover; upper has lushness and biodiversity, rich with mushrooms and big trees, protected by the roadless rule. See attached pic from a hike with my sister, admiring an old cedar. To drive an hour from the city and immerse myself into the alpine lakes is amazing - the air is clean. It's away from road noise, light pollution, run off. There are few invasives, like the rampant Himalayan Blackberry brambles tracked in by forestry trucks that choke out natives in the PNW. I can drink the melt water; there's no industry upstream. South in MBSNF is the headwater of Seattle's drinking supply, put ask risk by roads given the reality of industrial pollution from timber and mining. It's humbling, awe-inspiring, and spiritually moving for me to be immersed in these spaces. The woods has measurable therapeutic effects. I was in the Allegheny NF in PA recently, an area already logged, mined, and parceled, which is filled with invasive species choking out natives, like Japanese Knotweed. FS roads have oil derricks alongside streams. Camping has traffic sounds. This is not what WA needs! WA's roadless forests are a recreation hotspot - folks travel the world to climb our world-class alpine terrain, and to train for larger objectives like the Himalayas, or to backpack, like The Enchantments, adjacent to impacted Chelan NF; part of what makes this place special is it's wildness. Liberty Bell in Chelan NF just outside of N. Casc. NP, another area protected by the rule, is among the 50 Classic Climbs in North America, and the surrounding wilds impacted by the rule are home to some of the best climbing in WA, e.g., Early Winter and Kangaroo Spires. Last time I was there saw wildfires in N. Casc. NP - the road through the middle of the park didn't stop the spread of the fires; per Access Fund, "fuels reduction and fire management can occur in roadless areas, while, research indicates, expanding road networks increase human-caused ignition risks." I was married in Mt. Baker North, an area protected by the rule. 20 people flew in from around the world. We did day trips to a huge stand of old-growth douglas firs, to admire the volcanoes, to see pink salmon spawning. This is a special place that needs more environmental protection not less! Creative management, not expanded industry. Bottom line: WA's roadless forest are special, rich with biodiversity, ripe for recreation, and deserving of protection by the roadless rule. Think longer-term - keep the roadless rule. Allow future generations to cherish these spaces. Keep public land public and help slow industrialization. Listen to the people! Protecting public land has bipartisan support! Preserve the roadless rule.