Comment Analysis · Docket FS-2025-0001

FS-2025-0001-522651

Opposes rescissionA2 moderateSubstance 15/24Owed an answerPosted September 30, 2026 On Regulations.gov

In short: The comment documents specific deficiencies in the agency's analysis regarding bird habitat loss, wildfire ignition rates, and small entity economic impacts, while requesting that reliance interests and foreseeable plan amendments be included in the final 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

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

Wildlife Habitat
- “bird richness declines with road presence”
- “road-noise experiments... cut bird abundance by over a quarter”
- “31 percent of species avoiding the noise entirely”
- “advocate for wild spaces and creatures”
Recreation Tourism Public Use
- “The birds keep me coming back to the Olympic National Forest”
- “lost recreation benefit at a minimum of $6.1 million a year”
- “My decision about where to hike, watch birds, and spend money on recreation”
- “need to take antidepressants to even function”
Governance Policy Process
- “Soliciting reliance interests and then declining to weigh them”
- “cannot simultaneously declare a foreseeable consequence out of scope and invite the public to comment”
- “must be analyzed as part of this action, not deferred”
- “certifies no significant impact on small entities while... names outfitters, guides and tour operators as affected”
Forest Management Wildfire
- “Human-caused ignition density is 22.4 fires per million acres per year on roaded... against 3.0 inside the affected roadless areas”
- “human-caused ignitions increase in abundance with proximity to roads”
- “quantify the expected increase in human-caused ignitions from new road access”
- “weigh it against the claimed reduction in wildfire hazard”

What it names

National Forests: Olympic National Forest
Roadless areas: Green MountainJefferson RidgeJupiter RidgeUpper Skokomish

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The birds keep me coming back to the Olympic National Forest, the Hoh Rainforest, and the parks spread across the Olympic Peninsula. I go looking for all the native birds of the area, and the roadless country there, including Green Mountain, Jupiter Ridge, Jefferson Ridge, Lightning, and Upper Skokomish, is where that country still holds. Rescinding the 2001 Roadless Area Conservation Rule would put that directly at risk, and I oppose it. The agency's own environmental analysis documents what roads do to birds in forested habitat. The DEIS cites findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. Those findings describe exactly the kind of habitat I travel to the Olympic Peninsula to find. The areas I named, totaling tens of thousands of acres across the Olympic National Forest, still function as roadless habitat. I ask that the agency explain, specifically in its final analysis, how it weighs these documented effects on bird communities against the claimed benefits of the proposal. The agency's fiscal reasoning also does not hold up. The proposal certifies no significant impact on small entities while, by its own account, the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. That certification is reached by spreading losses across every small firm in the sector nationally rather than examining the outfitters and guides actually holding permits in the affected areas. The agency even concedes some firms may lose these receipts, yet still issues the certification. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. On reliance: 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. My decision about where to hike, watch birds, and spend money on recreation in Washington has been shaped by the protections the 2001 rule affords. Washington holds 139 inventoried roadless areas totaling 2,014,832 acres, and the rule's stability is part of what makes those areas worth planning around. Soliciting reliance interests and then declining to weigh them in the cost-benefit framework is not a serious accounting. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one. I am devastated that my tax dollars would be erroneously spent to destroy this pristine wilderness, and the agency's own road-maintenance figures give that concern concrete shape. The DEIS records that Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads. Road-building into currently roadless country would almost certainly raise ignition rates there, yet the agency has not quantified that increase or weighed it against the claimed wildfire hazard reduction that is used to justify the proposal. I ask that the agency quantify the expected increase in human-caused ignitions from new road access and weigh it against the claimed reduction in wildfire hazard. Finally, The proposed rule concedes that subsequent land management plan amendments and revisions "could increase the area where timber harvest and road construction would be allowed," declares changes to plans beyond the scope of the proposal, and then requests public comment on them (91 FR 53830). The agency cannot simultaneously declare a foreseeable consequence out of scope and invite the public to comment on it. That maneuver shelters the most significant likely outcome of rescission from analysis while still nominally seeking input. The foreseeable plan-amendment scenario, including expanded timber harvest across areas like those on the Olympic Peninsula, must be analyzed as part of this action, not deferred. I live in Washington state and am a year round frequenter of the National parks here. I have looked forward to exploring more of the parks nationwide. I am an advocate for wild spaces and creatures and feel it would be disastrous to open up these last remaining wild spaces to development for the sake of other animals as well as for the sanity of humans who spend too much time in artificial spaces and need to take antidepressants to even function. We need wild nature. We are also animals who are connected to the earth! We cannot continue to abuse and rape this planet!