Comment Analysis · Docket FS-2025-0001

FS-2025-0001-504222

Opposes rescissionPosted September 28, 2026 On Regulations.gov

Not scored for substance: the comment does not clear the floor of substantive signal.

Topics

  • Wildlife Habitat
    • “Roadless areas also protect wildlife and threatened plant and animal species”
    • “federally threatened Northern spotted owl hunts small mammals under cover of old-growth canopy”
    • “federally endangered gray wolf moves through these forests as an apex predator”
    • “federally threatened Bull Trout and the proposed Similarity of Appearance (Threatened) Dolly Varden occupy distinct niches”
  • Water Quality Quantity
    • “Roadless areas protect water availability and water quality”
    • “Water originates in the highest elevations and flows downslope through a network of named streams”
    • “The Middle Fork Nooksack River integrates these tributaries into a major watershed system”
    • “watershed function... are direct products of the Rule's regulatory prohibition”
  • Forest Management Wildfire
    • “most ignitions near roads are human-caused”
    • “human-caused ignitions were concentrated near roads”
    • “The further from a road, the fewer human-caused fires”
    • “protect large areas from invasive species and the risk of fires that follow road incursions”
  • Tribal Sovereignty
    • “Nooksack Tribe signed a Memorandum of Understanding with the U.S. Forest Service to co-manage”
    • “formalizing their ongoing role in the stewardship of these ancestral lands”
    • “agreement with the Nooksack Indian tribe”

What it names

Roadless areas
Middle ForkMt. Baker WestSouth ForkTwin Sisters
Works cited
10.1016/j.apgeog.2011.09.00410.1186/s42408-026-00450-2

The comment

As someone who has spent considerable time accessing national forests specifically in areas the 2001 Rule has kept outside the road system, I am in a position to observe that the qualities those areas retain — watershed function, interior acoustic character, landscape continuity — are not incidental but are direct products of the Rule's regulatory prohibition. Your statement1 Roadless areas in our national forests are absolutely mandatory for the preservation, health, and continuation of these invaluable treasures. They contribute to offset carbon, protect large areas from invasive species and the risk of fires that follow road incursions into pristine forests. Regarding fire, for example, most ignitions near roads are human-caused. One study found that human-caused ignitions were concentrated near roads, near the wildland-urban interface, and in high-road-density areas. Lightning-caused ignitions, by contrast, were concentrated away from roads and in lower-density areas. The further from a road, the fewer human-caused fires (Narayanaraj & Wimberly 2012; Aplet et al. 2026). — Wimberly, 2012 (https://doi.org/10.1016/j.apgeog.2011.09.004); Aplet et al., 2026 (https://doi.org/10.1186/s42408-026-00450-2) Roadless areas also protect wildlife and threatened plant and animal species. The wildlife communities reflect the vertical zonation of forest and alpine habitats. In the dense hemlock-fir forests, the federally threatened Northern spotted owl hunts small mammals under cover of old-growth canopy, while the federally threatened Marbled Murrelet nests in the largest trees. The federally endangered gray wolf moves through these forests as an apex predator, and the federally threatened North American wolverine ranges across high-elevation terrain. In streams and cold-water tributaries, the federally threatened Bull Trout and the proposed Similarity of Appearance (Threatened) Dolly Varden occupy distinct niches in the aquatic food web, with Chinook salmon moving through larger channels during spawning seasons. Above the forest, the federally threatened Mt. Rainier white-tailed ptarmigan inhabits alpine heather communities, where Suckley's cuckoo bumble bee, proposed for federal endangered status, pollinates alpine flowers. The proposed threatened Monarch butterfly passes through the area during migration, while the federally threatened Yellow-billed Cuckoo uses riparian corridors in lower elevations. Roadless areas protect water availability and water quality, increasingly critical as our planet undergoes wide fluctuations between drought and flood. Mt. Baker West spans 25,390 acres across the subalpine terrain of the Mt. Baker-Snoqualmie National Forest in Washington. The landscape rises from Bell Pass at 3,900 feet through a series of prominent ridges and peaks—Grouse Ridge, George Peterson Butte, Park Butte, and the Twin Sisters peaks reaching 7,000 feet—that form the South Fork Divide. Water originates in the highest elevations and flows downslope through a network of named streams: the Upper Middle Fork Nooksack River headwaters drain northward through Clearwater Creek, Rocky Creek, and Ridley Creek, while Skookum Creek, Bell Creek, Gallop Creek, Wallace Creek, Green Creek, Rankin Creek, and Cornell Creek carry water through the western and southern portions of the area. The Middle Fork Nooksack River integrates these tributaries into a major watershed system that defines the hydrology of this region. Finally, the Roadless Area Conservation Rule of 2001 established protections for the Mt. Baker West area, a 25,390-acre Inventoried Roadless Area, prohibiting new road construction and timber harvesting. In February 2023, the Nooksack Tribe signed a Memorandum of Understanding with the U.S. Forest Service to co-manage sections of the Mt. Baker-Snoqualmie National Forest, formalizing their ongoing role in the stewardship of these ancestral lands. The Roadless Rule for these national forests must be kept intact. Otherwise the dangers are incalculable - to flora, fauna, waters, agreement with the Nooksack Indian tribe, and with all the American people who actually hold these lands. PLEASE do not rescind the Roadless Rule. I have addressed some of the specific gaps in the Forest Service's EIS, and demand that the Roadless Rule not go into effect. Please listen to the forests. Thank you, Dana Jack

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