Comment Analysis · Docket FS-2025-0001

FS-2025-0001-461376

Opposes rescissionA2 moderateSubstance 10/24Owed an answerPosted September 21, 2026 On Regulations.gov

In short: The comment establishes that Roadless Rule Alternative 1 is the most effective option for limiting wildfire risk and protecting rural economies, citing specific DEIS findings that road density increases ignition rates and that new road construction costs will exceed revenue, while documenting the commenter's direct use of specific roadless areas in Washington.

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

Forest Management Wildfire
- “limiting wildfire risk”
- “probability, number, and frequency of wildfire starts also go up”
- “newly built roads may make wildfires more frequent and ignition hotspots”
Recreation Tourism Public Use
- “essential tourism income to rural communities”
- “regional and national draws for outdoor recreation”
- “lost visitor spending”
Economic Impact Fiscal
- “spending less taxpayer money”
- “income from resource extraction in roadless areas will not cover the cost”
- “increase existing revenue shortfalls for the Forest Service”

What it names

National Forests: Gifford Pinchot National Forest Wenatchee National Forest
Roadless areas: Dark DivideSawtooth

Attachments

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

Own letter

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeEA analysisAnalytical gapEvidenceRequestAlternative

I am writing to support Roadless Rule Alternative 1, and the maintenance in full of all roadless areas. According to the government’s own analysis this alternative is the most effective at limiting wildfire risk, continues to provide essential tourism income to rural communities, and is the most responsible approach to spending less taxpayer money, as the income from resource extraction in roadless areas will not cover the cost to tax payers of building and maintaining new roads. I am a frequent user of roadless areas in Washington including the Dark Divide (Gifford Pinchot National Forest), Angels Staircase (Sawtooth Inventoried Roadless Area, Okanogan-Wenatchee National Forest) and Alpine Lakes (Okanogan–Wenatchee National Forest and the Mt. Baker–Snoqualmie National Forest). I visit these areas several times a year as a cyclist and hiker, and share the trails there with hunters, motorbikes, and other off-road vehicles. These three roadless areas are regional and national draws for outdoor recreation because of their wild and remote beauty, and the ability to travel without permits and with a variety transportation, serving a different set of users than the backcountry areas of our national parks. Because these areas are realtiviely remote, most trail users spend time and money in adjacent towns (Packwood, Trout Lake and Twisp) whose economies are largely reliant on outdoor recreation. I am most concerned about how the recession of the roadless rule will increase wildfire risk, harm the economies of rural towns with large outdoor recreation sectors, and increase existing revenue shortfalls for the Forest Service – ultimately increasing burden on tax payers. Rescinding the Rule Increases Wildfire Risk •Increased Human Ignitions: The DEIS highlights that as road density increases, the probability, number, and frequency of wildfire starts also go up. Roadless areas currently have significantly lower ignition rates, approximately four times fewer than other forest lands, and remove this rule will lead to more wildfires, more loss of private property, and more harmful wildfire smoke affecting our families. •Limited Fuel Treatment Gains: Although the administration frames the rescission as a tool to expand fuel treatments, the Forest Service itself acknowledges that due to budgetary and terrain constraints, any increase in treatment capability will likely be modest at best. •Contradictory Claims: Despite the stated goal of improving wildfire response by enabling road access, the DEIS admits that newly built roads may make wildfires more frequent and ignition hotspots, undermining wildfire safety objectives. Rescinding the rule hurts rural economies •Recreation Value Loss: The Forest Service’s economic analysis predicts up to $9 million annually in lost visitor spending. This stems from reductions in trail-based and wildlife-related recreation in areas that would become less scenic or accessible. •Rural Community Strains: Repealing the rule could cost taxpayers and rural communities money, not just through lost tourism but also through higher maintenance burdens. Rescinding the rule increases tax payer costs and creates new construction and maintenance costs the Forest Services is unable to foot the bill for. •Revenue Shortfalls: The DEIS estimates that forest-related revenue increases from new timber sales would likely fail to cover the costs of constructing and maintaining the new roads needed to access remote areas. •Maintenance Backlog Growth: The proposal would further burden the Forest Service’s already substantial backlog of road maintenance, currently around $6.9 billion, adding more miles to the inventory without new funding. Please move forward with Roadless rule alternative 1 and maintain prohibitions in all inventoried roadless areas. Becca Book