Comment Analysis · Docket FS-2025-0001

FS-2025-0001-527358

Opposes rescissionA1 strongSubstance 17/24Owed an answerPosted October 1, 2026 On Regulations.gov

In short: The comment establishes that the agency's proposal to rescind the Roadless Area Conservation Rule contains internal contradictions regarding wildfire ignition rates and economic net benefits, fails to quantify management burdens outside existing regulatory exceptions, and violates NEPA by eliminating protective alternatives from the 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, Alternative, 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

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”
- “ignition density data already in its own environmental record”
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 road system already carries a $6.9 billion maintenance backlog”
Governance Policy Process
- “purpose statement written as deregulation, which eliminated every protective option”
- “cannot satisfy NEPA's requirement to consider a genuine range of alternatives”
- “must restate the purpose and need in terms of actual forest and watershed conditions”
Water Quality Quantity
- “1,522 municipal water intakes sit in watersheds containing affected roadless areas”
- “treats that water supply... as outside the scope of review by design”

What it names

National Forests: Olympic National Forest
Roadless areas: Glacier Peak BGlacier Peak KGlacier Peak LMt. Baker MaMt. Baker SouthMt. Baker West
Law cited: 36 C.F.R. Section 294.12

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeEA analysisAnalytical gapEvidenceRequestAlternative

Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The roadless forests of Washington state, including the stretches I named in the Olympic National Forest, the Gifford Pinchot, the Wenatchee, and the Mt. Baker-Snoqualmie, are the reason I am filing this comment against the proposed rescission of the 2001 Roadless Area Conservation Rule under Docket FS-2025-0001. Washington holds 139 inventoried roadless areas totaling 2,014,832 acres. The areas I listed, among them the 86,000-acre Olympic block, the 74,650-acre Chelan unit in the Wenatchee, and the combined Mt. Baker-Snoqualmie areas running from the 6,335-acre Wobbly unit to the 415,000-acre broader forest inventory, represent exactly what the 2001 rule was written to protect. I oppose the rescission in full. The agency frames this proposal partly as a wildfire and fuels management measure, implying that opening roadless areas to road construction will reduce fire risk. The agency's own record says the opposite. Its prior analysis 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." The roadless blocks in the Mt. Baker-Snoqualmie, including the Glacier Peak K unit at 47,269 acres, the Glacier Peak L unit at 14,084 acres, and the Glacier Peak B unit at 19,328 acres, sit in landscapes where that ignition differential is directly relevant. The agency must explain, with reference to DEIS Table 21, why this proposal departs from its own prior finding that road access raises rather than lowers human ignition rates, and must reconcile that departure with the ignition density data already in its own environmental record. The proposal also rests on timber and energy economics. The agency's own record 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." Against that baseline, the agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service, offset by recreation losses of at least $6.1 million a year and a net present value ranging from -$92 million to +$199 million, a span so wide it cannot establish a net benefit. The Forest Service road system already carries a $6.9 billion maintenance backlog. The units I named, including the 25,390-acre Mt. Baker West and the 24,847-acre Mt. Baker Ma, sit within a forest system that cannot maintain what it already has. How does the agency justify expanding that system when its own analysis cannot demonstrate the action produces a net economic gain? On the question of permitting and administrative burden, the agency contends the rule imposes constraints that prevent necessary management. But the rule as written already accommodates that management. The agency's own summary states it "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." The 8,676-acre Tumwater unit and the 6,570-acre Mt. Baker South unit are the kind of areas the existing exceptions were written to address. The agency must identify, with specificity, which management needs fall outside those existing exceptions, including those covering public health and safety, existing mineral leases, and community wildfire protection, and must quantify those burdens in the record rather than assert them. Finally, the alternatives analysis underlying this proposal is built on a purpose statement written as deregulation, which eliminated every protective option before comparison could occur. The agency dismissed alternatives with more protection as not responsive to the deregulatory executive orders, and eliminated the keep-boundaries option because it "would continue to restrict local decision-making discretion" and because analysing roadless values is "an administrative and legal burden for the agency." A purpose and need framed entirely around reducing regulatory requirements cannot satisfy NEPA's requirement to consider a genuine range of alternatives. Across the Pacific Northwest region, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. Rescinding the rule without honestly analysing a protective alternative treats that water supply, and every other roadless value, as outside the scope of review by design. The agency must restate the purpose and need in terms of actual forest and watershed conditions and carry at least one protective alternative through full analysis before this rulemaking proceeds further. Best, Sophia Simpson-Khan Olympia, WA