Comment Analysis · Docket FS-2025-0001

FS-2025-0001-481972

Opposes rescissionA2 moderateSubstance 13/24Owed an answerPosted September 25, 2026 On Regulations.gov

In short: The comment documents that the DEIS's wildfire and road impact analyses are internally inconsistent and lack regional quantification for the Mt. Baker-Snoqualmie National Forest, specifically regarding sediment, slope stability, and the health benefits of primitive recreation settings.

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

Public Health Wellbeing
- “mental health counselor”
- “therapeutic work in and around the roadless areas”
- “health value of unroaded settings”
- “public health benefits in the Cost Benefit Analysis”
Forest Management Wildfire
- “wildfire rationale is contradicted by the DEIS's own data”
- “ignition density in roadless areas of about 12 fires per million acres”
- “1.8 million acres of hazardous fuels reduction occurred inside roadless areas”
- “quantify any net fire-risk benefit of new roads”
Water Quality Quantity
- “North Fork Nooksack headwaters”
- “part of Bellingham's municipal watershed”
- “effects on sediment, slope stability, drinking water”
- “debris floods that destroyed homes”
Governance Policy Process
- “Forest plans are not a substitute for a binding rule”
- “plans 'do not compel action or authorize projects'”
- “separate the two and disclose, by forest”
- “about 99 percent of comments on the Notice of Intent opposed rescission”

What it names

Roadless areas: Canyon CreekMt. Baker West

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: EvidenceLegal

I am a mental health counselor in private practice in Bellingham, Washington. I train clinicians in the neurobiology of nature connection and am the author of a forthcoming book on the subject, Somatic Nature. I live and work downstream of the Mt. Baker-Snoqualmie National Forest. I support Alternative 1 (No Action) and oppose Alternatives 2 and 3. I ask the Forest Service to address each issue below individually in the Final EIS. For over a decade I have done therapeutic work in and around the roadless areas of the North Fork Nooksack and Baker Lake, and I helped develop Wild Whatcom, a Bellingham nonprofit that brought youth groups into these areas. It now serves over 3,000 participants a year, including 1,200+ public school students in Title 1 classrooms and students with disabilities. A Stanford study interviewing former participants five to ten years later found they credited the program with a lasting connection to nature, gains in self- and social esteem, and shaping major life choices (Clark, 2020). In my clinical observation, these benefits extend from participants to their families and community. 1.The wildfire rationale is contradicted by the DEIS's own data. The DEIS claims the rule limited management and so contributed to wildfire and forest-health problems. Yet its fire analysis (Table 21) reports ignition density in roadless areas of about 12 fires per million acres per year, under a third of the 42 on other National Forest System lands, and acknowledges human-caused ignitions increase near roads. The Economic Analysis concedes more road access could increase wildfires. And 1.8 million acres of hazardous fuels reduction occurred inside roadless areas under the rule. I ask the Final EIS to reconcile these findings with the purpose and need, and to quantify any net fire-risk benefit of new roads rather than assert one. 2.National rankings hide effects in steep, wet, unstable Western Cascades terrain. Whatcom County's portion of this forest holds roughly 91,000 roadless acres, including North Fork Nooksack headwaters, and the Mt. Baker West roadless area includes part of Bellingham's municipal watershed. Harvest and road-building in the Canyon Creek drainage in the 1950s-70s contributed to debris floods that destroyed homes west of Glacier in the 1990s. The forest already has roughly 2,000 miles of road, and the DEIS reports road maintenance funding below 20 percent of need. Yet the DEIS describes road effects only as "more likely" or "less likely," with no projected road miles, sediment, or landslide risk by region, though it quantified roads for the Tongass. I ask the Final EIS to provide regional projections of road construction and their effects on sediment, slope stability, drinking water, and salmon habitat, including rain-on-snow and unstable-slope terrain in the North Cascades. 3.The analysis should account for the health value of unroaded settings. Primitive and semi-primitive recreation settings are among the rule's nine roadless characteristics. Clinically, their therapeutic value depends on sustained quiet, absence of engine noise, and an intact landscape, conditions that help clients, especially young people, settle out of a stress response. Research agrees: a study of nearly 20,000 people found about two hours a week in nature was associated with better health and wellbeing (White et al., 2019, Scientific Reports), and weekly awe walks increased positive emotion and reduced daily distress in older adults (Sturm et al., 2020, Emotion). Roads and logging remove exactly these qualities; a roaded forest is not a substitute. I ask the Final EIS to analyze effects on primitive settings specifically and address their public health benefits in the Cost Benefit Analysis. 4.Forest plans are not a substitute for a binding rule. The DEIS relies on plans as the remaining protection, yet states plans "do not compel action or authorize projects" and future decisions depend on local interpretation. Its plan-restriction figures also merge binding standards with non-binding guidelines. I ask the Final EIS to separate the two and disclose, by forest, including the Mt. Baker-Snoqualmie, how many roadless acres would retain binding prohibitions on roads and timber harvest. By the DEIS's own count, about 99 percent of comments on the Notice of Intent opposed rescission. I urge the Forest Service to adopt Alternative 1 and keep the 2001 Roadless Rule. Matthew Fogarty, Bellingham, WA