Comment Analysis · Docket FS-2025-0001

FS-2025-0001-522997

Opposes rescissionA2 moderateSubstance 13/24Owed an answerPosted September 30, 2026 On Regulations.gov

In short: The comment establishes that the agency's justification for rescinding the 2001 Roadless Area Conservation Rule is contradicted by its own record regarding wildfire ignition rates on roaded lands, economic marginality of timber/oil yields, and unassessed reliance interests, specifically citing DEIS Table 21 and the Cost Benefit Analysis to document these deficiencies.

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
- “outdoor access to undeveloped forests and protected land”
- “backcountry ski, hike, and camp in Mt. Baker-Snoqualmie National Forest”
- “recreation losses of at least $6.1 million a year”
- “outfitters, guides and tour operators as affected”
Forest Management Wildfire
- “rescission serves wildfire and fuels management cannot survive its own record”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “increase in poor air quality from fire seasons”
- “Expanding road access into the roadless areas... does not reduce that risk. It compounds it.”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “net present value ranging from -$92 million to +$199 million”
- “Forest Service already carries a $6.9 billion maintenance backlog”
- “commodity yields the record itself describes as marginal”
Legal Regulatory Framework
- “regulatory flexibility certification compounds that problem”
- “certifies no significant impact on small entities”
- “agency should withdraw the certification and assess the impact on the small entities”
- “reliance interests in the current rule that could be affected by this proposal”

What it names

Roadless areas: Mt. Baker Noisy - DiobsudMt. Baker SouthMt. Baker West

The comment

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

I moved to Bellingham, Washington specifically for the outdoor access to undeveloped forests and protected land. That choice was deliberate, and the places I am writing about are not abstractions to me. I backcountry ski, hike, and camp in Mt. Baker-Snoqualmie National Forest most weekends. I backcountry ski in Mt. Baker West, a 25,390-acre inventoried roadless area, and in Mt. Baker South, which covers 6,570 acres. In the Mt. Baker Noisy - Diobsud area, I backcountry ski, hike, and bike. I also ride mountain bikes on the east side of the Cascades, and those backcountry trips are always some of my favorite memories from each year. These places are special to me and to my partner. I oppose the rescission of the 2001 Roadless Area Conservation Rule under Docket FS-2025-0001. The agency's stated justification that rescission serves wildfire and fuels management cannot survive its own record. The agency's own prior findings state: "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 have noticed an increase in poor air quality from fire seasons, and I know that even when fires burn in remote areas, they affect the air that millions breathe in major cities like Seattle. Expanding road access into the roadless areas where I ski and hike does not reduce that risk. It compounds it. The agency must explain in this proceeding why the proposal departs from that prior finding and must reconcile the rescission with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic case for rescission is just as difficult to square with the agency's own numbers. The record before the agency states: "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 to the Forest Service against recreation losses of at least $6.1 million a year, with a net present value ranging from -$92 million to +$199 million. The Forest Service already carries a $6.9 billion maintenance backlog on its existing road system. Washington alone holds 139 inventoried roadless areas totaling 2,014,832 acres, and across the Pacific Northwest, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. The agency should explain how expanding a road system with a known billion-dollar maintenance deficit, for commodity yields the record itself describes as marginal, constitutes sound stewardship of these landscapes. The regulatory flexibility certification compounds that problem. The proposed rule certifies no significant impact on small entities while, as the record itself shows, the DEIS names outfitters, guides and tour operators as affected and the Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. The supporting analysis reaches its no-impact conclusion by spreading expenditure losses across every small firm in the sector nationally rather than examining the outfitters and guides who actually hold permits in the affected areas, and it concedes that some firms may lose those receipts entirely. The agency should withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not a national average firm that has no permit at stake. Finally, the agency has invited comments on reliance interests. 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 one such interest. I moved to Bellingham because the rule existed and because it meant the forests where I ski and ride and camp would remain intact. That is a reliance interest the agency created and has not assessed. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. Sincerely, Nils Kingston Bow, WA