Comment Analysis · Docket FS-2025-0001

FS-2025-0001-531941

Opposes rescissionA2 moderateSubstance 15/24Owed an answerPosted October 1, 2026 On Regulations.gov

In short: The comment documents that the agency's DEIS and Cost Benefit Analysis contain specific data on increased wildfire ignition risks and localized economic harms that contradict the proposed rescission, and it requests that the agency quantify these impacts and properly weigh the stated reliance interests of local stakeholders.

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

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 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”
- “weigh that increase, clearly and transparently, against whatever wildfire hazard reduction it claims to pursue”
Water Quality Quantity
- “1,522 municipal water intakes sit in watersheds containing affected roadless areas”
- “businesses and communities depending on clean water face concrete exposure”
- “protecting the forests and waters that the public owns”
Economic Impact Fiscal
- “Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year”
- “spreading losses across every small firm in the sector nationally, rather than examining the outfitters and guides who actually hold permits”
- “subsidizing infrastructure that opens the last unroaded third of the national forests to extraction”
Environmental Protection Biodiversity
- “Old growth has already been depleted substantially”
- “protecting it feels less like policy to me and more like something owed to every person who comes after us”
- “Do not taint what is left with greed”

What it names

National Forests: Wenatchee National Forest
Roadless areas: ChelanHungry RidgeSlide Ridge

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The forests and lakes of Washington State are some of the most beautiful places in this country, and my family has camped at Chelan every year long enough that protecting it feels less like policy to me and more like something owed to every person who comes after us. The Chelan inventoried roadless area covers 74,650 acres inside the Wenatchee National Forest, and it sits alongside Stormy Mountain, Slide Ridge, and Hungry Ridge, among others, each one part of the 2,014,832 acres Washington holds across 139 inventoried roadless areas. I am filing this comment in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001), and I am asking that the agency take seriously what its own record says. Start with fire, because the proposal does not. The agency's own 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 agency's DEIS compounds this finding with hard numbers: "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." Washington is a state of astounding forests and lakes, and the people who live here do not need that landscape made more vulnerable to ignition. I ask that the agency quantify the expected increase in human-caused ignitions that would follow from new road access under this proposal and weigh that increase, clearly and transparently, against whatever wildfire hazard reduction it claims to pursue. The economic analysis does not hold together either. "The proposed rule certifies no significant impact on small entities while 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 was reached by spreading losses across every small firm in the sector nationally, rather than examining the outfitters and guides who actually hold permits in the specific roadless areas that would be opened. Across the Pacific Northwest, 1,522 municipal water intakes sit in watersheds containing affected roadless areas, which means the businesses and communities depending on clean water face concrete exposure that a national average conceals entirely. The agency must withdraw that certification, conduct a meaningful assessment of the small entities actually operating in the potentially affected areas, and stop hiding localized harm behind an aggregate that cannot see it. Taxpayers, including me, are tired of watching public money mismanaged to disproportionately fund roads for logging. The existing roads are already under-maintained, and the Forest Service is already a thinned agency. What is the purpose of adding more roads to create more strain across an institution that cannot adequately manage what it already has? Taxes should be dedicated to maintaining and protecting the forests and waters that the public owns, not to subsidizing infrastructure that opens the last unroaded third of the national forests to extraction. Old growth has already been depleted substantially. Once that remaining undeveloped land is gone, what is left? The future children of this country deserve at least a fraction of what once was, and I can guarantee that no average citizen wants to destroy more of what remains. Finally, 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 family's relationship to Chelan, to the Wenatchee, to the roadless character of these places, is precisely the kind of reliance interest the solicitation invites. The agency must identify and give genuine weight to the reliance interests described in the comments it receives, including this one, rather than soliciting them and then leaving them unweighed in the analysis that follows. Do not taint what is left with greed. The record you have built contradicts the action you are proposing, and the public is watching. Sincerely, Brooklynn Marshall WA