Comment Analysis · Docket FS-2025-0001

FS-2025-0001-571849

Opposes rescissionA2 moderateSubstance 14/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment documents the specific hydrological deficiencies in the agency's analysis regarding long-term summer flow deficits and road impacts on watershed resilience in the Mt. Baker–Snoqualmie National Forest, supported by cited scientific studies and local modeling reports, and requests the retention of the Roadless Rule with an alternative focused on intact-watershed protection.

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, Alternative.

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
- “natural water infrastructure”
- “watershed resilience and downstream water security”
- “Forest management is water management”
- “substantial summer-flow deficits”
Environmental Protection Biodiversity
- “intact forests and headwaters”
- “older, native, structurally complex forests”
- “ecological capital these forests already provide”
- “salmon recovery and watershed restoration”
Scientific Research Evidence
- “Perry and Jones (2017, Ecohydrology) analyzed sixty-year records”
- “2022 South Fork Nooksack forest-management and August-streamflow modeling report”
- “Long-term research makes the summer-flow concern especially clear”
- “paired-basin experiments in Oregon”
Forest Management Wildfire
- “Wildfire concerns require evidence specific to forest type”
- “road-related ignition risks and watershed costs”
- “existing exceptions are insufficient”
- “avoidable changes to runoff pathways”

What it names

Roadless areas: Middle ForkSouth Fork

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 placeLocal knowledgeEA analysisAnalytical gapEvidenceRequestAlternative

I strongly oppose rescinding the 2001 Roadless Area Conservation Rule. The remaining intact forests and headwaters on our national forests are natural water infrastructure. Removing their protections would put watershed resilience and downstream water security at risk. I live near the confluence of the North, Middle, and South Forks of the Nooksack River in Whatcom County, Washington. My work centers on watershed restoration and ecological forestry. I have spent approximately thirty years climbing and twenty years mountaineering. The Mt. Baker–Snoqualmie National Forest is a place I love and know intimately through years of returning to its mountains, forests, and headwaters. On visits to Deming Glacier, at the headwaters of the Middle Fork Nooksack, I have watched a substantial part of its lower portion disappear. Its meaning is immediate: the sources of stored water sustaining our watershed are changing. We need to protect the watershed functions we can protect. Forest management is water management. Water security depends on when water arrives, how quickly it moves, its temperature and quality, and how much remains during the driest months. More runoff during a winter storm does not resolve a shortage of cold water in August. Older, native, structurally complex forests have a living architecture that develops over centuries: layered canopies, diverse vegetation, large wood, roots, and intact soils. A plantation does not immediately replace those functions. Forest condition influences interception, evapotranspiration, soil water storage, snow processes, and the pathways connecting hillslopes to streams. Treating all tree cover as hydrologically interchangeable obscures these differences. Long-term research makes the summer-flow concern especially clear. Perry and Jones (2017, Ecohydrology) analyzed sixty-year records from eight paired-basin experiments in Oregon. Average July–September streamflow in basins with 34–43-year-old Douglas-fir plantations was approximately 50 percent lower than in reference basins with 150–500-year-old forests. That number should not be applied mechanically to every Washington watershed. It does demonstrate that converting older forests to plantations can produce substantial summer-flow deficits decades after cutting. The Forest Service must evaluate these long-term effects, including regrowth and repeated harvest, rather than emphasize initial runoff increases. The 2022 South Fork Nooksack forest-management and August-streamflow modeling report prepared for the Nooksack Indian Tribe also deserves consideration. Roads introduce another set of risks. Road surfaces, cut slopes, ditches, and culverts can intercept and reroute water, connect runoff to channels, and deliver sediment. Their hydrologic footprint extends beyond the driving surface. Closing a road to traffic is different from restoring its hydrologic function. Forest effects on flood peaks vary with storm magnitude, basin characteristics, and management. Intact forests cannot prevent every flood. Nevertheless, avoidable changes to runoff pathways, erosion, and sediment delivery deserve serious assessment. Uncertainty about a precise downstream effect is not a reason to ignore the mechanism or the cumulative pressure. These headwaters are connected to watersheds already affected by roads, development, and timber management across public and private lands. Private industrial timberlands must be included in the cumulative assessment. Remaining intact federal lands should strengthen watershed resilience. Opening them to additional disturbance risks undermining investments in salmon recovery and watershed restoration downstream. I ask the Forest Service to retain the Roadless Rule and evaluate an alternative that strengthens intact-watershed protection while prioritizing maintenance and restoration of existing roads. The analysis must address peak flows, summer low flows, baseflows, evapotranspiration, seasonal water yield, snow dynamics, sediment, temperature, and relevant groundwater pathways over decades. Wildfire concerns require evidence specific to forest type, treatment, and location. The agency must explain why existing exceptions are insufficient and compare claimed safety benefits with road-related ignition risks and watershed costs. Broad claims about management flexibility do not justify removing a national conservation safeguard. Our full balance sheet must include the ecological capital these forests already provide. Protecting their living architecture is an investment in public infrastructure and water security. I love these mountains, and I live downstream of them. Please protect the intact headwaters that sustain the rivers, salmon, and communities below.