Comment Analysis · Docket FS-2025-0001

FS-2025-0001-576855

Opposes rescissionA1 strongSubstance 16/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment documents that the agency's DEIS data (Table 21) contradicts the wildfire rationale for rescission, that the existing regulatory exceptions (36 C.F.R. § 294.12) already address the cited administrative burdens, and that the regulatory flexibility analysis and cost-benefit analysis fail to account for specific local economic impacts and reliance interests in named roadless 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

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
- “seeking beauty, grandeur, and the solitude”
- “lost recreation benefit at a minimum of $6.1 million a year”
- “support exactly these kinds of guided recreation businesses”
- “planning trips, taking photographs, sharing these places with my daughter”
Forest Management Wildfire
- “demolishes the wildfire rationale offered for this rescission”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “opening the Entiat or the Teanaway or Glacier Peak to new roads in the name of fire management is not a solution”
- “reports far higher fire density on roaded land than inside these areas”
Governance Policy Process
- “The regulatory flexibility analysis contains a contradiction the agency has not addressed”
- “The agency must explain why this proposal departs from its own prior findings”
- “The agency should withdraw that certification and assess the firms that actually operate”
- “The agency must identify and weigh the reliance interests described in the comments”
Environmental Protection Biodiversity
- “mountains, lakes, creeks, and wildlife I have spent years exploring”
- “Losing these roadless lands is irreversible and you cannot get the beauty back”
- “alpine terrain of Glacier Peak, with its lakes, meadows, and wildlife”
- “preserved for all future generations of Americans”

What it names

National Forests: Wallowa-Whitman National Forest Wenatchee National Forest
Law cited: 36 C.F.R. Section 294.12

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 mountains, lakes, creeks, and wildlife I have spent years exploring in Washington's roadless areas are precious, and the thought of any of it being opened to new roads and development is, simply, tragic. I hike all year round and backpack during the summer and fall months, seeking beauty, grandeur, and the solitude I can find in places like the Alpine Lakes Wilderness and adjacent areas in the Wenatchee National Forest, the Entiat, the Teanaway, and the Glacier Peak area in the Mt. Baker-Snoqualmie National Forest. I also hike the Olympic Mountains and Cascade Mountains and have backpacked in the Wallowa-Whitman National Forest in northeast Oregon. I take many pictures, especially during backpacking trips, and looking at my pictures and slideshows transports me back to the experiences of those trips. These are not abstractions. These roadless areas are where I go. The agency's own record demolishes the wildfire rationale offered for this 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." I know this dynamic in a direct way. A huge forest fire has already destroyed an area of the Entiat, all 72,617 acres of which lie in the Wenatchee National Forest, where I had hoped to backpack. Losing these roadless lands is irreversible and you cannot get the beauty back. If road construction increases ignition risk by the factor the agency's own data describe, opening the Entiat or the Teanaway or Glacier Peak to new roads in the name of fire management is not a solution. The agency must explain why this proposal departs from its own prior findings and reconcile the rescission with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside these areas. The permitting and administrative burden rationale fares no better under scrutiny. The rule already provides for exceptions, including for public health and safety. The agency's own text confirms as much: the rule "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." If the rule already accommodates those needs, the agency has not shown what specific burden remains that justifies removing protection from the 57,104 acres of Alpine Lakes Adjacent lands, the 72,849 acres of the Teanaway, or any of the other areas I rely on. Which specific burdens are not already addressed by the rule's existing exceptions, and what is the quantified weight of those burdens? The regulatory flexibility analysis contains a contradiction the agency has not addressed. 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. The alpine terrain of Glacier Peak, with its lakes, meadows, and wildlife, and the Teanaway, where the larch trees turn golden in a way that draws visitors every fall, support exactly these kinds of guided recreation businesses. A certification reached by spreading losses across every small firm in the sector nationally, rather than assessing the actual permit holders operating in these areas, does not satisfy the purpose of the analysis. The agency should withdraw that certification and assess the firms that actually operate in the affected roadless areas. Finally, the proposal itself invites comment on reliance interests and then the Cost Benefit Analysis weighs none. The agency solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. I have spent years hiking and backpacking in these areas, planning trips, taking photographs, sharing these places with my daughter, with friends, and alone, in reliance on the protection the 2001 rule provides. Our public lands should be managed for the people, as Theodore Roosevelt envisioned, and preserved for all future generations of Americans. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before it proceeds any further. Sincerely, Dick Crabb Seattle, Washington