Comment Analysis · Docket FS-2025-0001

FS-2025-0001-457357

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

Small family — One letter sent by 3 to 9 people, copied or lightly reworded. This comment stands for 3 submissions in its group. See the letter, its submissions and topics.

In short: The comment establishes that the commenter is a lifelong resident of Washington State who opposes the rescission of the Roadless Rule, citing specific local impacts on wildfire ignition density, watershed protection, and tribal resources.

Scored as the letter — The shared letter of a family, scored once for everyone who sent it.

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

Forest Management Wildfire
- “wildfire-ignition density was four times (4x) higher in lands that were within 50 meters of roads”
- “eliminating the roadless rule is not going to achieve that goal”
- “presence of roads equates to more potential fires in the first place”
Climate Carbon Storage
- “mature old growth trees that absorb and store carbon”
- “if these trees are logged, then that carbon gets released back into the atmosphere”
- “contributes to the climate crisis”
Water Quality Quantity
- “prevent the threat of contamination of protected watersheds”
- “Municipal drinking water is sourced from roadless areas”
- “more than 60 million people from 33 states getting their water from national forests”
Tribal Sovereignty
- “Native tribes strongly oppose eliminating the Roadless Rule”
- “additional roads and logging would threaten treaty resources”
- “sacred sites, and cultural places”

Attachments

3 files. Counts as 105 — Counted from the files: The enclosed submissions were counted from the files themselves.

Own letter
Enclosed submissions
Own letter

The comment

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

My name is Caitlin Birkland. I was born and have lived my entire life in Washington State. Here in Washington forests and wildlands are part of what makes the Pacific Northwest (PNW) what it is and because of that, I strongly oppose the proposal to fully or partially rescind the roadless area conservation rule (Roadless Rule) introduced by the Forest Service and the United States Department of Agriculture (USDA). The secretary of agriculture and the Forest Service have proposed rescinding the 2001 Roadless Area Conservation Rule citing wildfire risk management as the primary reason for eliminating protection of roadless areas. The claim is that when these areas catch fire, firefighters do not have access to and therefore cannot protect our forests from burning. It is true that over the last decade, at least here in Washington State, smoke from wildland fires (be that in Washington or in neighboring states/Canada), has increased. I completely understand and agree with the Forest Service and USDA's desire to reduce the intensity and frequency of these wildfires; however, eliminating the roadless rule is not going to achieve that goal. In an article published by the Association for Fire Ecology, it was concluded that wildfire-ignition density was four times (4x) higher in lands that were within 50 meters of roads and the further the distance from the road, the more the ignition density decreased. In other words, if there is a road, the likelihood that a fire will be ignited compared to a roadless area is greater BECAUSE of the presence of the road. Roads allow human access and humans ignite fires both accidentally and intentionally. Additionally, this article states that there is a difference in fire suppression methods used depending on the type of land. Land that contains valuable property, structures (e.g., homes) and resources are considered "High Value Resources and Assets (HVRA). When fires are ignited on lands that are considered HVRAs, naturally, resources are sent to that area to minimize destruction and/or loss of those assets. Wild lands and inventoried roadless areas (IRA) are so remote, that they do not typically fall into the category of HVRA. Therefore, when a fire is ignited on a roadless area or IRA, resources are not typically allocated to that area because there is nothing there that has been inventoried as worthy of allocating resources to and fires in these areas are allowed to self-extinguish. Given this information, resources are not spend protecting roadless areas anyway and why spend more money creating roads in roadless areas when the presence of roads equates to more potential fires in the first place? According to a draft Environmental Impact Statement (EIS) released by the USDA and Forest Service, it was reported that the Forest Service currently has 370,000 miles of road that they are responsible for maintaining, but a $6.9 billion backlog of deferred maintenance. To spend money on new roads when the Forest Service does not have the funds to maintain the roads they are currently responsible for does not make financial or economic sense. As a taxpayer, I would like to know how this project would be funded if the Roadless Rule was overturned and eliminated? Finally, there are other moral and environmental reasons why I am opposed to changing or eliminating the Roadless Rule as it currently stands. The first reason is that many roadless areas contain mature old growth trees that absorb and store carbon. If these trees are logged, then that carbon gets released back into the atmosphere and contributes to the climate crisis. Next, the Roadless Rule was originally put into place to prevent the threat of contamination of protected watersheds. Municipal drinking water is sourced from roadless areas with more than 60 million people from 33 states getting their water from national forests. Finally, Native tribes strongly oppose eliminating the Roadless Rule because additional roads and logging would threaten treaty resources, sacred sites, and cultural places. For all of the aforementioned reasons above, fully or partially rescinding the Roadless Rule under Alternatives 2 and 3 of the draft EIS would be a horrible mistake. For the purposes of transparency, the documents that I have referenced in my comment will be attached. I hope that the Forest Service and the USDA seriously evaluate the impacts of their proposal and make a decision that puts the needs and well-being of the people who would be directly impacted first. I am deeply opposed to the proposal to rescind or alter the Roadless Rule and will only support Alternative 1, the no action alternative. My opposition is supported by the majority of the public, most of us are in agreement that our roadless areas should remain that way. Thank you for your time and consideration.