Comment Analysis · Docket FS-2025-0001

FS-2025-0001-540339

Opposes rescissionA2 moderateSubstance 14/24Owed an answerPosted October 4, 2026 On Regulations.gov

In short: The comment documents specific deficiencies in the agency's analysis regarding wildfire ignition rates, water quality impacts on salmon, and the unsupported regulatory flexibility certification, while asserting the commenter's reliance interest based on backpacking in the named forests.

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

Water Quality Quantity
- “critical to watershed quality”
- “Road construction degrades water quality”
- “1,522 municipal water intakes sit in watersheds”
- “downstream effects of new road construction on watershed quality”
Wildlife Habitat
- “chinook salmon that depend on cold, clean water”
- “degraded water quality is habitat loss”
- “largest concentration of shorebirds in the Western Hemisphere”
- “Brown bear, moose, mountain goat, bald eagle... depend on a forest that has remained... without roads”
Forest Management Wildfire
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land”
- “quantify the expected increase in human-caused ignitions from new road access”
- “weigh that increase against whatever reduction in wildfire hazard is claimed”
Legal Regulatory Framework
- “regulatory flexibility certification is equally unsupported”
- “legal standard governing agency reversals”
- “change of course requires genuine accounting for what the prior policy caused people to rely upon”
- “agency must identify and weigh the reliance interests”

What it names

National Forests: Chugach National Forest Wenatchee National Forest

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 watersheds I backpack through are why I oppose rescission of the 2001 Roadless Area Conservation Rule. I travel across Oregon, Washington, and Idaho, including the Teanaway in the Wenatchee National Forest, lands managed as part of the Okanogan-Wenatchee National Forest, and the Chugach National Forest in Alaska. What happens to these areas is not abstract to me. The Teanaway and the surrounding drainages are critical to watershed quality and to the chinook salmon that depend on cold, clean water to survive. Chinook are a keystone species. Their economic value, their role as a food source, and their importance to other endangered species including orca whales make them far more than a recreational concern. Road construction degrades water quality, and degraded water quality is habitat loss for a population already fighting for survival. Across the Pacific Northwest, 1,522 municipal water intakes sit in watersheds containing affected roadless areas, according to DEIS Table 35. The people who drink that water, the hunters and fishermen who depend on healthy fish runs, and the outdoor users who travel these places all have a concrete stake in keeping roads out. I ask the agency to explain in its final analysis how it accounts for the downstream effects of new road construction on watershed quality and on species already listed as threatened or endangered. The Chugach is the most roadless national forest in the entire system. Ninety-nine percent of it has never had a road built through it, and it holds 40 inventoried roadless areas totaling 5,439,110 acres. The Copper River Delta hosts the largest concentration of shorebirds in the Western Hemisphere during spring migration. Brown bear, moose, mountain goat, bald eagle, trumpeter swan, and western sandpiper in the millions depend on a forest that has remained, overwhelmingly, without roads. Rescission removes the nationwide rule that has protected this condition and replaces it with nothing binding. The agency has not explained what mechanism, short of the 2001 rule, would prevent future road authorizations in a forest of this scale and ecological consequence. On fire, the agency's own findings are in direct conflict with the rationale offered for rescission. The DEIS 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." That is the agency's own text. The same record reports 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, and states that human-caused ignitions increase in abundance with proximity to roads. The proposal must quantify the expected increase in human-caused ignitions from new road access and weigh that increase against whatever reduction in wildfire hazard is claimed. The agency has not done this, and it cannot finalize the rescission without doing so. The regulatory flexibility certification is equally unsupported. 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. Spreading a $9 million annual expenditure loss across every small firm in a sector nationally does not assess the firms that actually hold permits in the affected areas and could actually lose those receipts. That certification should be withdrawn and replaced with an analysis of the small entities directly at risk. Finally, the agency has created and then ignored the reliance interests its own notice invited. The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" and the Cost Benefit Analysis weighs none. This comment is one such interest. Under the legal standard governing agency reversals, a change of course requires genuine accounting for what the prior policy caused people to rely upon. The agency must identify and weigh the reliance interests described in the record it is building, including this one, before it proceeds further. Sincerely, Sarah Trowbridge Seattle, WA