Comment Analysis · Docket FS-2025-0001

FS-2025-0001-579692

Opposes rescissionA2 moderateSubstance 9/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment documents that the agency's proposed rule contains internal contradictions regarding forest health and fire suppression efficacy, fails to isolate the impact of roads from suppression strategies, and underestimates cumulative recreation losses, thereby requesting specific reconciliations and alternative analyses before a final decision.

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.

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

Recreation Tourism Public Use
- “I hike and camp by the Pend Oreille lakes”
- “I want my children and grandchildren to have wild places”
- “potential annual losses for trail and dispersed area recreation”
- “estimate cumulative recreation losses over a meaningful time horizon”
Water Quality Quantity
- “Water is life”
- “more roads mean more sedimentation”
- “compromised water systems for wildlife and people”
Wildlife Habitat
- “I want them to experience wildlife”
- “compromised water systems for wildlife”
- “wildlife-related recreation”
Forest Management Wildfire
- “initial attack success rates would be expected to increase”
- “less-than-full suppression is used more often in roadless areas”
- “most new roads are expected to be temporary timber spurs”
- “No analysis in the document isolates the effect of roads from suppression strategy”

What it names

National Forests: Colville National Forest

The comment

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

The forest is right across the river from where I live, and that proximity makes this impossible to ignore. I hike and camp by the Pend Oreille lakes with my husband and grandkids, and I am filing this comment to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule as it affects the Colville National Forest and all inventoried roadless areas on National Forest System lands. The agency claims, in its Rationale for the Proposed Rule, that "The 2001 Roadless Rule limited the Forest Service’s ability to conduct vegetation management within inventoried roadless areas and has contributed to the lack of active management of the national forests, which has contributed to challenges in addressing forest health concerns." But the agency's own document also finds that the rule did not meaningfully constrain fuel treatments as a share of forested land, and that insect and disease risk in western roadless areas is similar to or lower than on managed forest land. These findings sit alongside the forest health rationale without any reconciliation. I ask the agency to explain, in its response, how that rationale holds when its own findings undercut it so directly. Water is life, and more roads mean more sedimentation and compromised water systems for wildlife and people. The agency claims in the Fire Control section that "With increased road access, initial attack success rates would be expected to increase." But the document shows that less-than-full suppression is used more often in roadless areas, which makes the initial attack comparison unreliable on its face, and the document further acknowledges that most new roads are expected to be temporary timber spurs rather than strategic fire roads. No analysis in the document isolates the effect of roads from suppression strategy. The agency must provide that separation and must estimate how many fire-useful roads are actually expected given real funding constraints. I want my children and grandchildren to have wild places. I want them to experience wildlife. That future depends on the agency taking recreation losses seriously. The document estimates, in the section on Economic Benefits from Recreation in Roadless Area Forests, that "Assuming an upper limit of a 1 percent annual loss of economic benefit within the likely operable and likely operable but complex areas translates into potential annual losses for trail and dispersed area recreation of $4.8 million and $1.3 million for wildlife-related recreation, nationally." But the same section acknowledges that the magnitude of losses is unknown, and that approximately 52 percent of certain recreation setting classes are more likely to be affected. Roads and changes to recreation settings accumulate and persist over decades. A single-year 1 percent cap cannot capture that reality when set against roadless recreation benefits of upwards of $1.5 billion. The agency should estimate cumulative recreation losses over a meaningful time horizon and compare them honestly with projected timber revenue before any final decision is made.