Comment Analysis · Docket FS-2025-0001

FS-2025-0001-580479

Opposes rescissionA2 moderateSubstance 13/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment establishes that the agency's regulatory flexibility analysis fails to account for specific local economic impacts on outfitters and guides in Olympic National Forest, ignores solicited reliance interests, fails to quantify the increased human-caused fire risk from new roads despite data showing higher ignition density on roaded land, and improperly excludes foreseeable timber harvest expansions from the environmental analysis.

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
- “camped there every year since”
- “favorite places on earth”
- “lost recreation benefit at a minimum of $6.1 million a year”
- “outfitters, guides and tour operators as affected”
Forest Management Wildfire
- “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”
- “human-caused ignitions increase in abundance with proximity to roads”
- “Road access that multiplies ignition density by a factor this large is not a neutral tradeoff”
- “forests are healthy enough to be worth returning to year after year”
Legal Regulatory Framework
- “agency's own cost accounting contradicts its regulatory flexibility conclusion”
- “withdraw the small-entity certification”
- “Planning and recreation decisions made in reliance on the 2001 rule deserve weight”
- “foreseeable plan-amendment scenario... belongs inside the environmental analysis”
Resource Development Extraction
- “could increase the area where timber harvest and road construction would be allowed”
- “expanded timber harvest is a foreseeable result of rescinding the rule”
- “new road construction”
- “industrial development”

What it names

National Forests: Olympic National Forest

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 Olympic National Forest has been part of my life since I was two years old. I have camped there every year since, and it is one of my favorite places on earth. This place is why I fell in love with the natural world. It has made me who I am today. That is the ground from which I oppose the rescission of the 2001 Roadless Area Conservation Rule in Docket FS-2025-0001. The agency's own cost accounting contradicts its regulatory flexibility conclusion. "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." That certification is reached not by examining the guides and outfitters who actually hold permits in the affected roadless areas, but by averaging a $9 million annual expenditure loss across every small firm in the sector nationally, a method the supporting analysis itself concedes may leave some firms absorbing the full loss of those receipts. Outfitters and guides operating in Olympic National Forest and forests like it are not a national average. They are specific businesses serving specific landscapes, and the rule change would reach them directly. I ask that the agency withdraw the small-entity certification and assess the impact on the businesses actually permitted and operating in the potentially affected roadless areas. Planning and recreation decisions made in reliance on the 2001 rule deserve weight here, and the agency has not given them any. "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." This comment is exactly the kind of reliance interest the solicitation invites. People who have built their relationship to these forests, their sense of where wild land would remain wild, around the protections the 2001 rule established are now asked to speak while the analysis treats their interests as weightless. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before it proceeds further. The agency's fire data argues against its own proposal, and the effects analysis does not resolve the contradiction. "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." I camp in Olympic National Forest because it remains intact, because its forests are healthy enough to be worth returning to year after year. Road access that multiplies ignition density by a factor this large is not a neutral tradeoff against claimed wildfire hazard reduction. The agency has not quantified what increase in human-caused fire can be expected from new road construction, nor weighed that increase against whatever hazard reduction it projects. That quantification must appear in the record before any decision is made. Finally, the agency has structured this proposal to avoid analyzing its most consequential foreseeable consequence. "The proposed rule concedes that subsequent land management plan amendments and revisions 'could increase the area where timber harvest and road construction would be allowed,' declares changes to plans beyond the scope of the proposal, and then requests public comment on them (91 FR 53830)." The agency cannot simultaneously treat plan amendments as beyond scope and invite the public to comment on them. If expanded timber harvest is a foreseeable result of rescinding the rule, it is part of this action, not a separate future matter, and the agency is asking commenters to do the analytical work it has declined to do itself. The foreseeable plan-amendment scenario, including the areas where timber harvest could expand, belongs inside the environmental analysis for this proposal, not outside it. Olympic National Forest made me who I am. I oppose this rescission, and I expect each of these failures of analysis to be addressed fully in the record. Sincerely, Alison Seattle, WA 98118