Comment Analysis · Docket FS-2025-0001

FS-2025-0001-579653

Opposes rescissionA2 moderateSubstance 15/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment establishes that the agency's DEIS fails to apply cited habitat fragmentation and wildfire ignition data to the full affected acreage, ignores the sediment impact on 1,522 municipal water intakes, and improperly certifies no significant economic impact on small entities despite quantified losses, while failing to evaluate the reliance interests of local users in the Enchantments and Okanogan-Wenatchee National Forest.

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

Wildlife Habitat
- “bird richness declines with road presence”
- “habitat fragmentation reduces biodiversity”
- “learning about birds, the American Pipit, the Dark-eyed Junco”
Water Quality Quantity
- “Water protection is among my highest priorities”
- “roads and their facilities can produce up to 90 percent of the sediment”
- “1,522 municipal water intakes sit in watersheds”
Governance Policy Process
- “No equivalent process is being conducted to undo it”
- “regulatory flexibility certification does not hold up”
- “identify and weigh the reliance interests”
Recreation Tourism Public Use
- “My family has hiked the Enchantments many times”
- “lost recreation benefit at a minimum of $6.1 million a year”
- “enjoy these same spaces with their own children”

What it names

National Forests: Wenatchee National Forest
Works cited: Kroeger et al. 2022

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 My family has hiked the Enchantments many times. A large photograph my son took of Lake Vivian on his graduation celebration hike hangs in our living room. My husband describes that area as a taste of heaven. I grew up in Cashmere, Washington, loving those natural spaces for exactly the reset they gave me. I now live in Spokane, and the older I get, the more I understand that protecting large areas of forest land is one of the most important actions we can take for the health of our entire planet. I oppose the rescission of the 2001 Roadless Area Conservation Rule. I support the no action alternative. Washington holds 139 inventoried roadless areas totaling 2,014,832 acres, including more than 1,006,000 acres in the Okanogan-Wenatchee National Forest. These are places my family returns to. We love learning about birds, the American Pipit, the Dark-eyed Junco, and the occasional eagle. The agency's own data give me serious reason to worry what road-building would do to them. The DEIS cites the finding that "bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. (source: DEIS; Kroeger et al. 2022; McClure et al. 2013; Ware et al.)" The DEIS also cites the finding that "habitat fragmentation reduces biodiversity by 13 to 75 percent." That range appears in the document and is never applied to the 40.1 million acres of potentially affected environment. I ask that the agency apply that fragmentation range to the full extent of the affected acreage before this rule moves forward. Water protection is among my highest priorities. Creating new roads sets off a chain reaction with countless negative consequences from logging. The quality of our lives is directly linked to our access to water free from contamination. Across the Pacific Northwest region alone, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. The agency acknowledges that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. I want the agency to explain on the record how it reconciles that figure with opening these watersheds to new road construction. The process behind this rescission troubles me as much as the substance. More than 600 public meetings and 1.6 million comments shaped the original rule. No equivalent process is being conducted to undo it. So many people spoke up to get the roadless rule in place, and we should be working to protect even more wild spaces, not rolling back the protections we currently have. The proposal 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. My family's relationship with these forests is exactly the kind of reliance interest the agency invited and has not evaluated. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one. The agency's own fire record weakens the case for opening these areas. "Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads." The agency has not quantified the expected increase in ignitions that new road access would bring or weighed that against the claimed reduction in wildfire hazard. That analysis must be done before any decision is made. Finally, the regulatory flexibility certification does not hold up. "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 certification is reached by spreading losses across every small firm nationally rather than assessing the guides and outfitters actually permitted in the affected areas. The agency should withdraw the certification and assess the operators who actually work in these places. Being in nature and photographing it helps to experience transcendent moments. More and more research shows connections between access to trees and wildlife and increased cognition and mental health. I want my children to grow up and enjoy these same spaces with their own children. Short-term profit is not worth the damage that will be done if we lose these protections. Please protect these sacred places. Sincerely, Tamara Kennedy-Gibbens Spokane, WA