Comment Analysis · Docket FS-2025-0001

FS-2025-0001-580049

Opposes rescissionA1 strongSubstance 15/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment establishes that the DEIS's justification for removing 11 million acres of inventoried roadless areas under Alternative 3 is unsupported by the record because the analysis applies a 0.5-mile road buffer criterion rather than the stated RARE II mapping-error rationale, and fails to distinguish between pre-2001 roads and post-2001 construction.

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

Environmental Protection Biodiversity
- “protecting our most fragile ecosystems”
- “decline in Pacific salmon populations”
- “protects fragile ecosystems from further degradation”
Water Quality Quantity
- “severe flooding and associated landslides”
- “sediment carried downstream causes erosion”
- “protecting watersheds”
Legal Regulatory Framework
- “RARE II Mapping-Error Rationale Unsupported”
- “0.5-Mile Road-Buffer Criterion Actually Applied”
- “factual correction and a supplement to the environmental analysis”
Climate Carbon Storage
- “more suited to sequestering carbon”

What it names

Law cited: 7 C.F.R. 1b

The comment

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

I live in Washington State. I oppose the rescission of this rule protecting our most fragile ecosystems. I am retired from 34 years of service with the Mt Baker Snoqualmie National Forest. During my tenure the area experienced severe flooding and associated landslides the majority originating from old logging roads. These slides entered salmon streams and were a contributing factor to the decades long decline in Pacific salmon populations. In addition the sediment carried downstream causes erosion and loss of life and property. The roadless rule protects fragile ecosystems from further degradation. Most of the areas designated as roadless do not support timber suitable for sawlogs or any other extractive industry, they have all been tried. Unlike industrial forest land at lower elevations, most of the land designated roadless is more suited to sequestering carbon, and protecting watersheds. RARE II Mapping-Error Rationale Unsupported by the 0.5-Mile Road-Buffer Criterion Actually Applied The DEIS's stated basis for removing roaded inventoried roadless areas under alternative 3 is not the basis the analysis actually applies, and the difference is 11 million acres. At page 24 the DEIS explains why roaded areas sit inside the 2001 inventory: "These roaded areas were included as inventoried roadless areas under the 2001 Roadless Rule because of mapping errors in RARE II and road construction between the time RARE II was completed and the 2001 rule." That sentence states a historical finding - that the acreage is inside the inventory by error or by pre-2001 construction - and it is the DEIS's justification for removing that acreage under alternative 3. The analysis does not support it, for three reasons drawn from the DEIS's own text. 1. The operative criterion is not a mapping-error correction. At page 25 the DEIS states the criterion actually applied: "Roaded inventoried roadless areas were defined as the area within 0.5 miles (either side) of existing roads." That is a proximity buffer run against a current road layer. It performs no comparison to RARE II-era mapping, identifies no specific mapping error, and produces no finding that any particular acre was erroneously inventoried in 2001. 2. The data cannot distinguish the categories the sentence relies on. Footnote 10 at page 25 defines "existing roads" as "National Forest System roads and other authorized public roads." Footnote 20 at page 43 states that "the roads data of September 2025 is used for analyses," drawn from the Forest Service Natural Resource Manager database. A September 2025 road layer records where roads are now. It cannot distinguish a road that existed when RARE II was completed from one built after 2001, and the DEIS's own next sentence at page 24 confirms that post-2001 construction occurred: "some road construction occurred between 2001 and 2010 while the rule was enjoined, or pursuant to the 2001 Roadless Rule's exceptions." A road built lawfully under the Rule's own exceptions is the opposite of a mapping error; it is the Rule operating as designed. On this record no portion of the removed acreage is attributable to RARE II mapping error, because no analysis capable of attributing it was performed. 3. Most of the buffered acreage is not roaded. Land lying within half a mile of a road is not itself roaded. The DEIS removes "6.3 million acres of roaded roadless and 4.7 million acres that are both within the wildland-urban interface and within 0.5 miles of existing roads" (p. 25), and nowhere discloses how much of that 11 million acres contains a road as opposed to lying inside the buffer. The distinction is not academic. Under alternative 3, "roads could not be constructed outside of roaded roadless or wildland-urban interface areas" (p. 88), which means new road construction is permitted inside them. The acreage removed under a "roaded" label is the acreage opened to new roads. These are a factual correction and a supplement to the environmental analysis, within 7 C.F.R. 1b.7(f)(2)(iii) and (v), and the response should cite where in the final EIS each is accounted for under 7 C.F.R. 1b.7(f)(3). The same defect goes to the explanation supporting the proposed rule: if the Department adopts modified inventoried roadless area boundaries on the stated ground that the acreage was inventoried in error, the record must support that ground, and as it stands it does not.