Comment Analysis · Docket FS-2025-0001

FS-2025-0001-570135

Opposes rescissionA2 moderateSubstance 14/24Owed an answerPosted October 5, 2026 On Regulations.gov

In short: The comment establishes that the agency's proposal to rescind the Roadless Area Conservation Rule contradicts its own published data in DEIS Table 21 regarding wildfire ignition rates on roaded lands, fails to reconcile its economic analysis which shows a potential net loss and an unfunded maintenance backlog, and relies on a regulatory flexibility certification that ignores the specific local economic impacts on small entities in the Methow Valley and Liberty Bell areas.

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 wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “The proposal nonetheless invokes wildfire and fuels management as grounds for opening roadless areas to new road construction”
Economic Impact Fiscal
- “The agency receives less than 20% of the funds needed annually to maintain the existing road infrastructure”
- “recreation losses of at least $6.1 million a year and a net present value ranging from -$92 million to +$199 million”
- “The existing road system already carries a $6.9 billion maintenance backlog”
Legal Regulatory Framework
- “The Tenth Circuit held: "In sum, we conclude that the Roadless Rule did not designate de facto administrative wilderness areas"”
- “the 2001 rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act”
- “The regulatory flexibility analysis that certifies no significant impact on small entities cannot survive contact with the rest of the record”
Recreation Tourism Public Use
- “I go there for solitude”
- “Liberty Bell is a legendary gem of Washington's North Cascades that deserves the protections it has”
- “outfitters, guides and tour operators as affected”

What it names

National Forests: Wenatchee National Forest
Roadless areas: Liberty Bell

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Methow Valley and the Liberty Bell Inventoried Roadless Area are what brought me to this docket. I go there for solitude. Liberty Bell is a legendary gem of Washington's North Cascades that deserves the protections it has, and the Okanogan-Wenatchee National Forest surrounding it is one of the broadest, most diverse assemblages of habitat, recreation opportunities, and a deep source of economic stability for local communities. The proposal to rescind the 2001 Roadless Area Conservation Rule would strip those protections from Liberty Bell's 108,495 acres and from the 1,006,000 acres of the Okanogan-Wenatchee as a whole. I oppose it. The agency's own findings on fire undermine its primary justification for rescission. The 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." The proposal nonetheless invokes wildfire and fuels management as grounds for opening roadless areas to new road construction. That rationale contradicts the agency's own ignition data, which DEIS Table 21 reports as showing far higher fire density on roaded land than inside the affected roadless areas. The agency must explain, with specificity, why its current proposal departs from those prior findings, and must reconcile the rescission with the data it gathered and published in its own environmental review. The economic case for rescission is no stronger. The agency acknowledges: "The agency receives less than 20% of the funds needed annually to maintain the existing road infrastructure. As funding needs remain unmet, the cost of fixing deteriorating roads increases exponentially every year." Against that admission, the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year, set against recreation losses of at least $6.1 million a year and a net present value ranging from -$92 million to +$199 million. The existing road system already carries a $6.9 billion maintenance backlog. An action whose own analysis cannot establish a net benefit, and whose implementing agency cannot fund the roads it already has, cannot be justified by economic grounds. I ask the agency to reconcile the proposal with those numbers before it proceeds. On statutory authority, a court has already resolved the question the proposal reopens. The Tenth Circuit held: "In sum, we conclude that the Roadless Rule did not designate de facto administrative wilderness areas in contravention of the procedures set out in the Wilderness Act." That court further held the 2001 rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act. The proposal argues the rule exceeded the agency's authority. What is the legal basis for that position in light of the circuit court holding? The agency must address this directly. Finally, the regulatory flexibility analysis that certifies no significant impact on small entities cannot survive contact with the rest of the record. The proposal 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. The certification is reached by spreading expenditure losses across every small firm in the sector nationally rather than examining the outfitters, guides and permit holders actually operating in the affected areas. The analysis itself concedes some of those firms may lose those receipts entirely. Washington alone holds 139 inventoried roadless areas totaling 2,014,832 acres, and across the Pacific Northwest, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. The economic reach of this rescission is not abstract or evenly distributed. The agency should withdraw the certification and conduct a genuine assessment of the small entities actually holding permits and operating in these places, not a national average that obscures the local harm. Liberty Bell and the Okanogan-Wenatchee are worth protecting because of what they are. The agency has not made the case, by its own numbers or by law, that rescission improves on that. Sincerely, Tony Cannistra, Ph.D. Winthrop, Washington