Comment Analysis · Docket FS-2025-0001

FS-2025-0001-583349

Opposes rescissionA1 strongSubstance 13/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment documents that the DEIS fails to project sediment delivery to 7,000 municipal intakes, identify enforceable forest plan provisions equivalent to 36 CFR 294.12/294.13, or apply cited biodiversity fragmentation rates to the 40.1 million acres of affected environment, while also asserting that the small entity certification ignores specific local outfitters and ignores the agency's road maintenance backlog.

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, 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

Water Quality Quantity
- “watched what road creation does to water”
- “Sedimentation, degradation of habitat, increased water temperature”
- “1,522 municipal water intakes sit in watersheds containing affected roadless areas”
- “People downstream of those intakes are drinking that water”
Environmental Protection Biodiversity
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
- “The Liberty Bell area has a character that comes precisely from its freedom from roads”
- “degradation of habitat”
- “no projection across the 40.1 million acres of potentially affected environment follows it”
Recreation Tourism Public Use
- “I hike and ski in the Liberty Bell area frequently”
- “It is a gorgeous zone that would be completely changed if roads were allowed”
- “lost recreation benefit at a minimum of $6.1 million a year”
- “guides and outfitters who work in areas like Liberty Bell”
Governance Policy Process
- “the agency's own analysis makes that plain while declining to follow the logic through”
- “The agency must identify, forest by forest, which plan provisions are equivalent”
- “The certification should be withdrawn and the impact assessed”
- “The final record should address this directly”

What it names

National Forests: Okanogan National Forest
Roadless areas: Liberty Bell
Law cited: 36 CFR 294.12

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 The Baker River and its tributaries, the alpine lakes throughout the region, the Liberty Bell area: these are not abstractions to me. I work in restoration, and I have watched what road creation does to water. Sedimentation, degradation of habitat, increased water temperature. I have seen these things. Rescinding the 2001 Roadless Area Conservation Rule will produce more of them, and the agency's own analysis makes that plain while declining to follow the logic through. The DEIS acknowledges that skid roads, trails, log landings and similar disturbances within timber sale areas are the main cause of soil erosion and "can contribute up to 90 percent of the sediment generated by timber sale activity." That number is stated and then left hanging. No projection of sediment delivery follows it. Across the Pacific Northwest region alone, which includes Washington, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. People downstream of those intakes are drinking that water. I ask that the agency quantify projected sediment delivery to the more than 7,000 municipal intakes downstream of these areas and explain in the final record how that delivery is controlled under the proposed rescission. The drinking water problem runs deeper than sediment. The DEIS states: "Approximately 24 million people use water originating within the potentially affected roadless areas, through more than 7,000 municipal intakes, and less than 12 percent of these watersheds are currently impaired." The document then asserts that forest plans address public drinking water, but it does not identify a single enforceable provision in any of those plans equivalent to what the rule currently requires. We have a responsibility to manage our public lands for people, water quality, and habitat. That responsibility cannot be discharged by a general reference to forest plans that are never examined. The agency must identify, forest by forest, which plan provisions are equivalent to 36 CFR 294.12 and 294.13 for municipal watersheds. I hike and ski in the Liberty Bell area frequently. It is a gorgeous zone that would be completely changed if roads were allowed. Liberty Bell sits within the Okanogan National Forest and covers 108,495 acres. Washington holds 139 inventoried roadless areas totaling 2,014,832 acres, and what happens to the rule happens to all of them. On the biology The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. That range is wide enough to span catastrophe, yet no projection across the 40.1 million acres of potentially affected environment follows it. The Liberty Bell area has a character that comes precisely from its freedom from roads and the development roads enable. The agency should apply the cited fragmentation range to the 40.1 million acres of potentially affected environment and explain what outcome it considers acceptable. On the economics, 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 guides and outfitters who work in areas like Liberty Bell are not a national average. Spreading an expenditure loss across every small firm in the sector to reach a no-impact conclusion does not assess the firms actually holding permits in the affected areas. The certification should be withdrawn and the impact assessed for the small entities actually operating in the potentially affected roadless areas. One further point: I don't think it makes sense to build more roads when the agency can't keep up with maintenance of the roads it already has. The agency is aware of its maintenance backlog. Building new roads into country that currently has none, while that backlog grows, transfers a long-term liability to the public and to the watersheds those roads will drain into. The final record should address this directly. Sincerely, Walker Brown Bellingham, WA 98225