Comment Analysis · Docket FS-2025-0001

FS-2025-0001-485705

Opposes rescissionA2 moderateSubstance 13/24Owed an answerPosted September 28, 2026 On Regulations.gov

In short: The comment documents that the agency's draft environmental impact statement contains internal contradictions regarding wildfire risk and economic benefits, specifically citing DEIS Table 21 and Cost Benefit Analysis data, and asserts that the rescission fails to weigh the reliance interests of the public and protect 1,522 municipal water intakes in the Pacific Northwest.

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, Evidence.

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

Recreation Tourism Public Use
- “places I love most are ones where roads have not yet followed”
- “sense of peace and quiet out there”
- “recreation losses of at least $6.1 million a year”
- “family plans trips around the existence of these protected places”
Water Quality Quantity
- “1,522 municipal water intakes sit in watersheds containing affected roadless areas”
- “Opening these forests to roads risks water quality through pollutants”
- “how those 1,522 intakes will be protected if roadless protections are lifted”
Forest Management Wildfire
- “Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “Managing that fuel load does not require building roads for the general public to drive through”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue against recreation losses”
- “Forest Service is already $6.9 billion behind on maintaining the roads it has”

What it names

National Forests: Gifford Pinchot National Forest Olympic National Forest
Roadless areas: Boulder RiverHiggins MountainMt. Baker SouthMt. Baker West

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequestAlternativeLegal

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The places I love most are ones where roads have not yet followed. I camp with my family near national parks, hike into forests where running water moves through old growth, and photograph rivers, waterfalls, creeks, and lakes. There is a sense of peace and quiet out there that it is impossible to get elsewhere, even in a rural agricultural area. I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule filed under Docket FS-2025-0001, and I ask this agency to answer the specific points below before it acts. Washington holds 139 inventoried roadless areas totaling 2,014,832 acres. I have a personal connection to several of them. Olympic National Forest holds 86,000 roadless acres and was one of the first national forests I visited on my own. I have hiked there, and I believe the number of roads it currently has is enough to sustain the area. The roadless areas of Mt. Baker-Snoqualmie National Forest, including Pressentin at 14,545 acres, Higgins Mountain at 13,185 acres, Mt. Baker West at 25,390 acres, Boulder River at 32,563 acres, Mt. Baker South at 6,570 acres, and Mt. Baker Noisy-Diobsud at 56,039 acres, together represent the kind of country where I go to find running water and towering trees. Gifford Pinchot National Forest contributes another 213,000 acres. The beauty of the roadless areas should be preserved. Across the Pacific Northwest region, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. Opening these forests to roads risks water quality through pollutants, plant life through greater exposure to invasive species, wildlife through noise and light, and air quality. I ask that the agency address how those 1,522 intakes will be protected if roadless protections are lifted. The agency's own findings on fire contradict its stated justification for this rescission. The 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." I agree that fire season is a serious problem, but it is serious in large part because controlled burns were suppressed for hundreds of years, allowing fuels to accumulate. Managing that fuel load does not require building roads for the general public to drive through. I ask that the agency explain why this proposal departs from its own prior findings and reconcile the rescission with the ignition data in its own draft environmental impact statement, DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic case for rescission is not made. 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." The agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year and a net present value spanning negative $92 million to positive $199 million. Meanwhile, the Forest Service is already $6.9 billion behind on maintaining the roads it has, on a road budget of about $73 million a year. Maintain the roads we have, connecting the neighborhoods and communities we already have. That will do more good for the country than adding roads. The agency must reconcile this proposal with a Cost Benefit Analysis that cannot establish a net benefit while expanding a road system already carrying that backlog. Finally, The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. This comment is such a reliance interest. My family plans trips around the existence of these protected places. The rule was built on more than 600 public meetings and 1.6 million public comments; it has shaped how people like me understand and use these forests for more than two decades. Not just our children, but our children's children down to seven generations from now deserve to inherit these spaces. The agency must identify and weigh the reliance interests expressed in the comments it receives, including this one. Sincerely, Julie Clark Coupeville, WA