Comment Analysis · Docket FS-2025-0001

FS-2025-0001-457807

Opposes rescissionA1 strongSubstance 15/24Owed an answerPosted September 21, 2026 On Regulations.gov

In short: The comment places on the record specific data regarding the 5% fuels treatment rate, a $6.9 billion maintenance backlog, and a 2026 University of Washington study on water protection to argue that the proposed rescission of the 2001 Roadless Area Conservation Rule is unsupported by the record and would negatively impact water quality, wildfire risk, and fiscal responsibility in Washington state.

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

A1 strong: Must be answered — it names the law.

Owed an answer on Analytical gap, Evidence, Legal.

Standard dismissals it defeats

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.
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.
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.

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.
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.

Topics

Water Quality Quantity
- “rivers and watersheds that supply clean drinking water”
- “protects drinking water for about 25 million Americans”
- “rely on water that comes exclusively from roadless areas”
Economic Impact Fiscal
- “deferred maintenance backlog of roughly 6.9 billion dollars”
- “funded to maintain only about a fifth of the more than 370,000 miles of road”
- “fiscally reckless and shifts the long term cost onto taxpayers”
Forest Management Wildfire
- “record does not support that”
- “greater access can increase human caused ignition potential”
- “Removing road protections is more likely to raise fire risk than lower it”
Resource Development Extraction
- “route powerlines, pipelines, and water conveyance through roadless corridors”
- “removing the road construction barrier”
- “full analysis of the industrial infrastructure this could enable”

What it names

Law cited: Executive Order 14154

The comment

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

I am writing to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (RIN 0596-AD66) and to urge the Department of Agriculture to retain the rule by selecting the No Action alternative. My name is Katie Uberti and I live in the greater Seattle area in Washington state. Washington contains 830 trails encompassing 4,000 miles that are currently protected by the Roadless Rule. These include acres in the North Cascades, sections of the Pacific Crest Trail and Lake Quinault and the surrounding rain forest. These places have provided my family some of our best days together and I want to see these sacred areas preserved. The rescission is justified as a wildfire measure, but the record does not support that. The agency's own analysis shows only about 5 percent of high hazard roadless areas have received fuels treatment since 2014, which reflects a budget and staffing shortfall, not a barrier created by the rule. The proposed rule also concedes that greater access can increase human caused ignition potential, and most wildfires on Forest Service land are started by people. Removing road protections is more likely to raise fire risk than lower it. Roadless areas also include rivers and watersheds that supply clean drinking water to 354 municipal watersheds. A 2026 University of Washington study, in partnership with Conservation Science Partners, found that the roadless rule protects drinking water for about 25 million Americans. The city of Port Townsend, WA, for example, could be particularly impacted by any new construction or logging because they rely on water that comes exclusively from roadless areas. Repealing the Roadless Rule also doesn’t make sense financially. The Forest Service already carries a deferred maintenance backlog of roughly 6.9 billion dollars for its roads and bridges, and it is funded to maintain only about a fifth of the more than 370,000 miles of road it already manages. This rescission opens up to 18.2 million acres to new road construction the rule currently prohibits. Building more roads the agency cannot afford to maintain is fiscally reckless and shifts the long term cost onto taxpayers. Finally, this rescission would make it far easier to route powerlines, pipelines, and water conveyance through roadless corridors by removing the road construction barrier that has kept most such infrastructure out. The Department cites Executive Order 14154 on energy as a reason for the action. The public deserves a full analysis of the industrial infrastructure this could enable, not an assurance that the effects would be modest. For these reasons, I ask the Department to: retain the 2001 Roadless Area Conservation Rule by selecting the No Action alternative; fully analyze the fiscal, wildfire, water, wildlife, and infrastructure effects described above; and complete meaningful Tribal consultation before any decision is made. These areas deserve our protection and reverence, not a bulldozer. I hope to see this administration listen to its constituents and retain the Roadless Area Conservation Rule. Thank you.