Comment Analysis · Docket FS-2025-0001

FS-2025-0001-558254

Opposes rescissionA1 strongSubstance 14/24Owed an answerPosted October 5, 2026 On Regulations.gov

In short: The comment places on the record specific geographic locations in Washington, cites DEIS Table 21 and 70 Fed. Reg. 25,656 to highlight internal contradictions regarding wildfire risk and economic benefits, and requests the agency to reconcile these findings before rescinding the Roadless Area Conservation Rule.

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, Evidence, 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

Water Quality Quantity
- “glaciers on Mount Baker feed the water I drink”
- “1,522 municipal water intakes sit in watersheds containing affected roadless areas”
- “More roads mean more pollution, more sediment, and more degradation of the clean fresh water”
Environmental Protection Biodiversity
- “pristine forests disrupted by clear cutting and deforestation drive all wildlife away”
- “full natural habitat that all animals depend on”
- “Gaping areas where all vegetation has been cleared do not make nature more beautiful”
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”
- “reconcile the rescission with its own ignition data in DEIS Table 21”
Recreation Tourism Public Use
- “landscape I move through to take photographs, to ride, to camp, to breathe fresh air”
- “recreation losses of at least $6.1 million a year”
- “take only photographs and leave only footprints”

What it names

Roadless areas: Boulder RiverGlacier Peak IHiggins MountainMt. Baker Noisy - DiobsudMt. Baker NorthMt. Baker SouthMt. Baker WestPrairie MountainWhite Chuck Mountain
Law cited: 28 U.S.C. Section 1291

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 glaciers on Mount Baker feed the water I drink. I live at the base of that mountain, and the roadless areas surrounding it, including Mt. Baker Noisy - Diobsud at 56,039 acres, Mt. Baker West at 25,390 acres, Boulder River at 32,563 acres, and Mt. Baker North at 16,873 acres, along with Pressentin, Higgins Mountain, Mt. Baker South, Prairie Mountain, Glacier Peak I, and White Chuck Mountain, are the landscape I move through to take photographs, to ride, to camp, to breathe fresh air. My ethic for all of it is simple: take only photographs and leave only footprints. I am filing this comment to oppose the rescission of the 2001 Roadless Area Conservation Rule under Docket FS-2025-0001. Washington holds 139 inventoried roadless areas totaling 2,014,832 acres. What I see in the places I described above is that pristine forests disrupted by clear cutting and deforestation drive all wildlife away. When I go out to photograph wildlife, what I want to see is trees, plants, and the full natural habitat that all animals depend on. Gaping areas where all vegetation has been cleared do not make nature more beautiful, and making more roads does not change that. The agency should explain on the record why it believes the opposite. The proposal invokes wildfire management as a reason to rescind this rule. The agency's own record 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 finding directly contradicts the premise that road-building serves fire safety. I ask that the agency reconcile the rescission with its own ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas, and explain what justification remains for departing from its own prior findings. The proposal also rests on an economic argument for timber access. 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." 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 and a net present value spanning -$92 million to +$199 million. The road system already carries a $6.9 billion maintenance backlog. Clear cutting, in my view, is simply stupid when the numbers do not support it. The agency must explain how an action whose own analysis cannot establish a net benefit justifies expanding that backlog further. My water comes directly from a glacier on Mount Baker. Across the Pacific Northwest region, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. More roads mean more pollution, more sediment, and more degradation of the clean fresh water that people here depend on. This is not abstract to me. The agency must address why this hydrological risk, documented in its own analyses, is being discounted in favor of an action whose economic case is, at best, uncertain. The agency argues that state-by-state approaches can replace a national rule. The record before the agency includes its own prior statement that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." But the agency's own record also acknowledged that local decision-making can incrementally reduce nationally significant roadless values, and the Ninth Circuit identified deficiencies the last time the agency tried replacing the national rule with a state-by-state approach. The agency should explain how this proposal avoids those same deficiencies. Finally, on the question of statutory authority, the agency's own appellate record contains this holding: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The Tenth Circuit found the 2001 rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. The agency owes a specific explanation, grounded in law, for any position that departs from that holding. Our forests do not need more roads. We need more people cleaning up. I ask the agency to deny this rescission. Sincerely, Christina Danielson Deming Washington