Comment Analysis · Docket FS-2025-0001

FS-2025-0001-509630

Opposes rescissionA1 strongSubstance 14/24Owed an answerPosted September 29, 2026 On Regulations.gov

In short: The comment establishes that the DEIS's rationale for rescinding the Roadless Rule is contradicted by its own data in Tables 14 and 21, which show lower insect/disease risk and significantly lower human-caused fire ignitions in IRAs compared to managed lands, thereby documenting a specific factual deficiency in the agency's forest health and wildfire analysis.

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, 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

Scientific Research Evidence
- “The DEIS's Own Tables 14 and 21 Contradict the Forest-Health Causal Chain”
- “percentage of forested acres at risk of mortality from insects and disease is lower in IRAs”
- “human-caused ignitions are nearly eight times higher outside IRAs”
- “arbitrary and capricious under 5 U.S.C. § 706(2)(A)”
Forest Management Wildfire
- “face greater fire risk due to roads and added access”
- “ignitions increase in abundance with proximity to roads”
- “1.8 million acres of hazardous fuels reduction within IRAs”
- “Restoring road access introduces the very variable associated with a vastly higher human ignition rate”
Environmental Protection Biodiversity
- “variety and quantity of wild nature”
- “lose their wild character”
- “uniform layer of protection against road construction and commercial timber harvest”
- “open Blue Lake to road construction and ground disturbance”
Legal Regulatory Framework
- “Forest plans provide the legal framework for managing national forests”
- “arbitrary and capricious under 5 U.S.C. § 706(2)(A)”
- “formal factual correction under 7 CFR 1b.7(f)(2)(v)”
- “rule-level premise used to eliminate alternatives”

What it names

National Forests: Gifford Pinchot National Forest
Roadless areas: Blue Lake
Law cited: 284 F.3d 1062 463 U.S. 29 66 FR 3244 7 CFR 1b

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 gapEvidenceRequestAlternativeLegal

Here is a revised, high-impact version that preserves all your facts, statutory references, data, citations, and personal connection while paring down the character count significantly. Dear Chief Tom Schultz: As someone who has spent a career weighing irreversible decisions against reversible ones, I take this rescission seriously. I love showing my children what makes the USA unique—our variety and quantity of wild nature. When these areas lose their wild character and face greater fire risk due to roads and added access, they lose their inherent value. Regarding Blue Lake in the Gifford Pinchot National Forest, Washington: Forest plans provide the legal framework for managing national forests under the National Forest Management Act of 1976. The Roadless Rule supplements these plans by adding a uniform layer of protection against road construction and commercial timber harvest across all inventoried roadless areas (IRAs) (USDA Forest Service, 2001, 66 FR 3244). Rescinding the Roadless Rule would open Blue Lake to road construction and ground disturbance, making specific comments on this area necessary. It is wrong and shortsighted. The DEIS’s Own Tables 14 and 21 Contradict the Forest-Health Causal Chain The Rationale for the Proposed Rule asserts that the 2001 Roadless Rule limited active management, contributing to forest health challenges (DEIS p. 19). The DEIS’s own data directly contradict this logic: Insect and Disease Risk: Table 14 (p. 75) shows that the percentage of forested acres at risk of mortality from insects and disease is lower in IRAs than in actively managed NFS lands outside designated areas across key western regions: Northern (34.2% in IRAs vs. 50.4% outside), Southwestern (13.5% vs. 17.5%), Pacific Southwest (15.2% vs. 18.9%), and Pacific Northwest (23.5% vs. 34.7%). As the DEIS notes (p. 75), risk is "similar or lower in potentially affected IRAs." Fire Risk and Road Access: Table 21 (p. 98, 2014–2024 data) shows human-caused ignitions are nearly eight times higher outside IRAs (22.4 fires per million acres/year) than within IRAs (3.0), while natural ignitions are also higher outside (16.8 vs. 8.5). The DEIS explicitly notes that ignitions "increase in abundance with proximity to roads." Restoring road access introduces the very variable associated with a vastly higher human ignition rate. Lack of Active Management Premise: The DEIS records an average of 500 acres/year of timber harvest and 1.8 million acres of hazardous fuels reduction within IRAs over the last decade (p. 15). Yet the agency concedes there is "no national-level tracking of the review, approval, or implementation of 2001 Roadless Rule exceptions" (p. 14) and that mortality on IRAs cannot be characterized nationally (p. 75). Asserting a causal link while failing to track exceptions or mortality outcomes is unsupported. An explanation that runs counter to the evidence before the agency is arbitrary and capricious under 5 U.S.C. § 706(2)(A) (Motor Vehicle Mfrs. Ass’n v. State Farm Mut. Auto. Ins. Co., 463 U.S. 29, 43 (1983); see also Kern v. BLM, 284 F.3d 1062 (9th Cir. 2002)). I request a formal factual correction under 7 CFR 1b.7(f)(2)(v) reconciling the Rationale with Tables 14, 21, and pp. 14–15—either by withdrawing the forest-health causal chain or detailing region-by-region where IRAs suffer worse health outcomes than actively managed lands. This cannot be deferred to project-level NEPA, as it forms the rule-level premise used to eliminate alternatives. If retained in the FEIS, state which acres and regions support this assertion and account for the response under 7 CFR 1b.7(f)(3). Please make the right choice, Laura Gahan