Comment Analysis · Docket FS-2025-0001

FS-2025-0001-577118

Opposes rescissionA3 weakSubstance 10/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment documents that specific roadless areas in the Mt Baker Snoqualmie, Nez Perce-Clearwater, Chugach, Tongass, El Yunque, and Allegheny National Forests are ecologically unsuitable for timber harvest and road construction, and that the proposed rule lacks specific written directions to protect wildlife from increased motorized recreation.

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

A3 weak: Substantive, but easier to set aside.

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.
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.
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.
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

Wildlife Habitat
- “negative impacts on salmon habitat, wildlife habitat”
- “displace essential wildlife such as wolverines, mountain goats, grizzly bears, and elk”
- “protection of fisheries and wildlife habitat”
- “degrade the wildlife habitat”
Recreation Tourism Public Use
- “local economy developed more reliance and infrastructure to support recreation”
- “far more valuable and suited for back country recreation”
- “diminish precious backcountry recreation”
- “recreational enjoyment and the well-being of our wildlife”
Water Quality Quantity
- “subject to landslides in zero order drain ages”
- “protection of critical wildlife habitat and watershed resources”
- “risk to the highly valuable fisheries resource”
- “adjacent to the Allegheny River, The Clarion Wild and Scenic River”
Governance Policy Process
- “I dispute that removing the roadless area rule would return decision making... to the land management planning process”
- “under timber harvest goals set at higher organizations”
- “absence of specific written directions in the plan to protect wildlife”
- “absence of defined limits on the extent of motorized trails”

What it names

National Forests: Allegheny National Forest Chugach National Forest Nez Perce-Clearwater National Forest Siskiyou National Forests Tongass National Forest

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequestAlternative

As a former US Forest Service employee with extensive experience in and adjacent to Roadless Areas, I strongly object to rescission of the the Roadless Area rule. I worked on the Mt baker Snoqualmie National Forest from 1980 through 1991. I worked on the Nez Perce National Forest in 1978 I worked on the Silver Fire Recovery Forest in the Siskiyou National Forest in 1987. I worked on the Hurricane Hugo Watershed Recovery Project in the El Yunque National Forest in 1989 I currently live in PA and have traveled and recreated in the Allegheny National Forest. I lived in Alaska in 2010 and traveled in Se Alaska in 1982 and throughout Alaska during my work for the Alaska Center for the Blind and Visually Impaired. Many of the roadless areas especially on the Mt Baker Snoqualmie National Forest were in areas not well suited to timber harvest. They occupied steep landscapes in the Silver Fir zone, areas that did not recover well from timber harvest and were often subject to landslides in zero order drain ages and due to failure of roads in the steep unstable terrain. Timber removal in these landscapes resulted in negative impacts on salmon habitat, wildlife habitat and yielded relatively little value for the timber harvested with the cost of harvest. I dispute that removing the roadless area rule would return decision making for the management of inventoried roadless areas to the land management planning process at the individual national forest level.Each National Forest and Ranger District has been under timber harvest goals set at higher organizations, not because of the true ability of the land to withstand the impacts of road construction and timber harvest. The Darrington Ranger District of the Mt Baker Snoqualmie National Forest where I worked for nearly a decade is a prime example. Areas open to timber harvest had excessive road construction, often poorly maintained and subject to slope failures. Once the levels of timber harvest were reduced in Darrington and Monte Cristo the local economy developed more reliance and infrastructure to support recreation that utilized back country and front country resources. The areas proposed to be removed from the Roadless Area Rule in the Darrington Ranger District are generally adjacent to wilderness, on lands not well suited to road construction and timber harvest. They are far more valuable and suited for back country recreation, protection of fisheries and wildlife habitat. The Roadless Areas of the Nez Perce Clearwater National Forest Striking a balance between recreational enjoyment and the well-being of our wildlife is crucial for ensuring the long-term health of the Nez Perce-Clearwater National Forest. Roadless areas are designated for increased ATV, motorcycle, and snowmachine use, which will displace essential wildlife such as wolverines, mountain goats, grizzly bears, and elk. The absence of specific written directions in the plan to protect wildlife from increased motorized recreation raises questions about the sustainability of such expansion. Most named wildlife require extensive habitat. the absence of defined limits on the extent of motorized trails or riding areas leaves these critical zones vulnerable to an unlimited influx of motorized recreation. The roadless areas of the Nez Perce Clearwater like the Chugach Tongass and Mt Baker Snoqualmie National Forests are far more valuable for protection of salmon habitat than they are for timber harvest. The Chugach National Forest Roadless areas are located in areas not well suited to timber harvest. Much of the landscapes steep sloped areas with soil that is destabilized by road construction, posing a risk to the highly valuable fisheries resource. The Tongass National Forest in Alaska is well suited to insure the long term protection of the salmon and other fisheries, and wildlife. The Tongass not unlike the Higher elevation roadless areas on the Mt Baker Snoqualmie and Siskiyou National Forests does not support timber harvest and regrowth to justify the cost and environmental impact of that harvest. The EL Yunque National Forest has roadless areas. They are a vital resource for protecting critical wildlife habitat and watershed resources. There are ample areas of the El Yunque National Forest to serve the needs of the casual tourist. The Allegheny National Forest is a precious resource to Pennsylvanians. Opening up current Roadless areas to road construction and energy development would degrade the wildlife habitat and diminish precious backcountry recreation. The Roadless areas are adjacent to the Allegheny River, The Clarion Wild and Scenic River, within the Allegheny National Recreation Area and the Hickory Creek Wilderness. I strongly object to rescission of the Roadless Area Rule. These roadless areas are a unique and irreplaceable resource belonging the people of the United States. They are part of our heritage and should be retained in current condition.