Comment Analysis · Docket FS-2025-0001

FS-2025-0001-568287

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

In short: The comment establishes that the proposed rescission of the 2001 Roadless Area Conservation Rule is fiscally irresponsible due to the Forest Service's existing $5 billion deferred maintenance backlog, scientifically unsupported regarding wildfire risk given human ignition patterns, and procedurally deficient compared to the 2001 rulemaking, urging the adoption of the No Action alternative to protect specific roadless areas in Washington State.

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

Recreation Tourism Public Use
- “trail running, backpacking, and climbing”
- “intact backcountry that makes this state's public lands worth living near”
- “outdoor recreation economy that depends on undeveloped landscapes”
- “quiet trails”
Forest Management Wildfire
- “wildfire rationale offered for this rescission is unsupported”
- “Extending roads into currently roadless areas is more likely to increase ignitions”
- “The 2001 rule already allows fuel-reduction treatments”
- “counterproductive on fire”
Governance Policy Process
- “process here does not justify overturning the rule”
- “public was given 45 days... to digest a 300-page draft environmental impact statement”
- “commenters overwhelmingly supported keeping roadless protections”
- “urges the Department to withdraw this proposal”
Water Quality Quantity
- “Roadless areas protect drinking water sources”
- “clean rivers”
- “sediment-shedding liability”

What it names

Roadless areas: Dark Divide
Law cited: 36 CFR part 294

Attachments

1 file. Counts as 1 — Counts as one: The attachments enclose no one else's submissions; the comment counts as one.

Own letter

The comment

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

I am writing to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. I urge the Forest Service to adopt the No Action alternative and retain 36 CFR part 294, subpart B. I live in Seattle and spend much of my life in Washington's national forests, trail running, backpacking, and climbing in the Mt. Baker-Snoqualmie, Olympic, and Gifford Pinchot National Forests. Washington holds roughly two million acres of inventoried roadless areas, including places like the Dark Divide and the Kettle River Range. These are not abstract acres on a map to me. They are the intact backcountry that makes this state's public lands worth living near. They also anchor an outdoor recreation economy that depends on undeveloped landscapes, clean rivers, and quiet trails. First, the Forest Service cannot maintain the infrastructure it already has. The agency manages more than 370,000 miles of roads and carries a deferred maintenance backlog of more than $5 billion. USDA's own Inspector General found that the agency has been unable to reduce that backlog and lacks a strategy to do so. Anyone who uses national forest trails sees the result: washed-out tread, blowdown left for seasons, and access roads degraded past passenger-car use. Opening 45 million more acres to road construction would add permanent maintenance liabilities to an agency that already cannot meet its obligations. Every new road mile built under this rescission will eventually become another deteriorating, sediment-shedding liability that taxpayers fund and no one maintains. Second, the wildfire rationale offered for this rescission is unsupported. Peer-reviewed research found that humans started 84 percent of U.S. wildfires over two decades, and human ignitions concentrate where people can drive. Extending roads into currently roadless areas is more likely to increase ignitions than to reduce fire risk. The 2001 rule already allows fuel-reduction treatments and access for fire suppression, so rescission is not necessary to meet the wildfire goals the Department cites. Third, the process here does not justify overturning the rule. The 2001 rule emerged from one of the largest public engagement efforts in the agency's history, with hundreds of public meetings and well over a million comments. By contrast, the public was given 45 days, including a 15-day extension, to digest a 300-page draft environmental impact statement for a rule affecting tens of millions of acres. The Department's own analysis of comments on last year's Notice of Intent found that commenters overwhelmingly supported keeping roadless protections. The record before the agency points in one direction, and it is not rescission. Roadless areas protect drinking water sources, salmon habitat, and the last undeveloped backcountry in the National Forest System. Rescinding these protections would be fiscally irresponsible, counterproductive on fire, and contrary to the clearly expressed will of the public. I urge the Department to withdraw this proposal and select the No Action alternative.