Comment Analysis · Docket FS-2025-0001

FS-2025-0001-462557

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

In short: The comment establishes that the agency's proposal to rescind the Roadless Area Conservation Rule contradicts its own DEIS findings regarding wildfire ignition rates on roaded lands, fails to demonstrate a net economic benefit given a $6.9 billion maintenance backlog, and lacks specific identification of forest plan provisions equivalent to 36 CFR 294.12 for protecting municipal drinking water sources in named areas like the South Kalmiopsis and Quilcene.

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

Recreation Tourism Public Use
- “Hiking and camping on the Olympic Peninsula and near my hometown in Southern Oregon is how I stay connected to the world around me”
- “local communities treasure it and depend on it for outdoor recreation and tourism”
- “Losing the Quilcene, all 18,656 acres of it, would be an unfathomable loss”
- “recreation losses of at least $6.1 million a year”
Water Quality Quantity
- “Our public lands should be managed for watershed and drinking water protection”
- “Clean drinking water is a fundamental right, and protecting the watersheds that generate so much of it must be a government priority”
- “Approximately 24 million people use water originating within the potentially affected roadless areas”
- “The South Kalmiopsis, which I have known since childhood, drains into communities that depend on those waters”
Wildlife Habitat
- “The unique ecosystem there positively teems with rare flora and fauna as well as unique geological features”
- “Our public lands should be managed for... wildlife habitat”
- “protecting the watersheds that generate so much of it must be a government priority above competing commercial interests”
Economic Impact Fiscal
- “the financial irresponsibility of building new roads when existing roads cannot be maintained is plain”
- “it is the height of fiscal recklessness to take on new construction we cannot afford”
- “projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year”
- “expanding a road system already carrying a $6.9 billion maintenance backlog”

What it names

National Forests: Olympic National Forest
Roadless areas: South Kalmiopsis
Law cited: 36 C.F.R. Section 294.12 36 CFR 294.12

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 placeLocal knowledgeEA analysisAnalytical gapRequest

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Hiking and camping on the Olympic Peninsula and near my hometown in Southern Oregon is how I stay connected to the world around me and enjoy time with friends and family. The areas I know, the South Kalmiopsis in the Siskiyou National Forest and the Quilcene in the Olympic National Forest, are not abstractions. I have been hiking in the South Kalmiopsis since I was a small child. The unique ecosystem there positively teems with rare flora and fauna as well as unique geological features, and local communities treasure it and depend on it for outdoor recreation and tourism. Losing the Quilcene, all 18,656 acres of it, would be an unfathomable loss. I oppose the rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001) and ask that this letter be entered into the record. Our public lands should be managed for watershed and drinking water protection, wildlife habitat, and outdoor recreation. Logging and mining special interests should not have more of a voice than the American people in decisions about these lands. The proposal before the agency tilts exactly that direction, and the agency's own analysis does not support it. The proposal invokes wildfire as a justification for opening roadless areas to road construction. 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." This is the agency's language, not mine, and it directly contradicts the rationale being offered for rescission. I ask that the agency explain why this proposal departs from its own prior findings, 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. On the economics: the financial irresponsibility of building new roads when existing roads cannot be maintained is plain. We are already behind on maintaining the roads that exist, and it is the height of fiscal recklessness to take on new construction we cannot afford. The agency's own record acknowledges that "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." I ask that the agency reconcile the proposal with its own cost-benefit analysis, which projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million, and that it explain how an action whose own analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog. The agency also cites administrative burden and permitting constraints as reasons for rescission. But the rule itself provides that it "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." The exceptions are already there. The agency has not shown which specific burdens fall outside them. I ask that the agency identify which burdens are not already addressed by the rule's existing exceptions, including those for public health and safety, existing mineral leases, and community wildfire protection, and that it quantify those burdens with specificity. Clean drinking water is a fundamental right, and protecting the watersheds that generate so much of it must be a government priority above competing commercial interests. The agency's own record states: "Approximately 24 million people use water originating within the potentially affected roadless areas, through more than 7,000 municipal intakes, and less than 12 percent of these watersheds are currently impaired." Oregon alone holds 211 inventoried roadless areas totaling 1,937,741 acres, and across the Pacific Northwest region 1,522 municipal water intakes sit in watersheds containing affected roadless areas. The South Kalmiopsis, which I have known since childhood, drains into communities that depend on those waters. The agency claims that forest plans already address municipal drinking water sources, but it has not identified a single enforceable plan provision equivalent to 36 CFR 294.12 and 294.13. The agency must identify, forest by forest, which plan provisions provide equivalent protection for municipal watersheds. I ask that each of these points receive a substantive response before any final action is taken. Sincerely, Marissa Litak Seattle, WA