Comment Analysis · Docket FS-2025-0001

FS-2025-0001-592810

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

In short: The comment establishes that the Draft EIS fails to provide quantified projections for road construction, sedimentation, and landscape fragmentation across the majority of the potentially affected environment, creating an inconsistency with the agency's stated reliance on quantified national harvest targets under Executive Order 14225 and the One Big Beautiful Bill Act, and requests supplemental analysis under 7 CFR 1b.7(f)(2)(iii) to meet NEPA requirements.

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

Legal Regulatory Framework
- “42 U.S.C. 4332(2)(C) requires a detailed statement”
- “supplement analysis under 7 CFR 1b.7(f)(2)(iii)”
- “reasonably foreseeable environmental effects”
- “Executive Order 14225 and on the One Big Beautiful Bill Act”
Environmental Protection Biodiversity
- “landscape fragmentation”
- “sedimentation”
- “road construction”
- “natural features like Mt Townsend”
Recreation Tourism Public Use
- “hiked and camped in roadless areas”
- “impact trails”
- “Olympic National Forest”
- “Quilcene”
Resource Development Extraction
- “timber harvest on those roads”
- “increase in total sawtimber harvest”
- “sell at least 250 million board feet more”
- “increase in timber production nationally by 25 percent”

What it names

National Forests: Olympic National Forest Tongass National Forest
Law cited: 42 U.S.C. 4332 7 CFR 1b Executive Order 14225

The comment

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

As a Washington State resident who understands firsthand what the Roadless Rule protects where I live, I oppose this rescission. I have hiked and camped in roadless areas across the Olympic National Forest, including Quilcene, and have studied the history of previous deforestation in the area. Rescinding the Rule would impact trails and natural features like Mt Townsend, where road construction is currently illegal, and timber harvest on those roads. The Draft EIS states the purpose of the proposed rescission in terms of "changing and localized conditions, such as increasing wildfire risk, the spread of insect and disease infestations, and the need for community protection in the wildland-urban interface" (DEIS Vol. I, p. 18), and asserts that the 2001 Roadless Rule "has contributed to the lack of active management of the national forests" (p. 19). The rescission would lift the 2001 Rule's prohibitions from approximately 44.7 million acres of National Forest System lands, with a potentially affected environment of 40.1 million acres under alternative 2 and 27.2 million acres under alternative 3 (p. 29). The DEIS does not translate that purpose into a quantified projection of the road construction, sedimentation, or landscape fragmentation the rescission would enable, and it says so itself: "Across the resources evaluated in the DEIS, the potential effects of increases in road construction and timber harvest activities are described in a general, programmatic, and qualitative way" (p. 30). For timber it goes as far as a nationwide range ("a 4 to 10 percent increase in total sawtimber harvest" (p. 30)) and then only "it is expected that some portion of that increase may occur within the potentially affected environment" (p. 79). For road miles, sedimentation, and fragmentation it supplies no projection at all. Table 3 reports the existing condition (about 9,500 miles of road within the potentially affected IRAs) and the acreage on which land management plans would allow road construction (18 million acres under alternative 2; 14 million under alternative 3), but no estimate of miles that would be constructed, no sediment delivery estimate, and no change in patch or core-area metrics. This is not a limit of the analytical method, because the DEIS performs the quantified work for one forest. It states that "[t]he environmental impacts presented in the other sections of the DEIS are programmatic and nationwide in nature," while the 2020 Alaska Roadless Rule FEIS "provides more specific, localized effects analysis for the Tongass National Forest affected environment, which supplement the broader nation-wide analysis" (p. 238). Carrying that analysis forward, the DEIS reports "an estimated 49 miles more of potential new road constriction [sic] within the Tongass compared to leaving the Roadless Rule in place" and an average road density of 0.23 miles per square mile (p. 239). By the DEIS's own accounting the Tongass is "nearly 1/4 of the potentially affected inventoried roadless area acreage" (p. 238). One quarter of the analysis area therefore receives a projected road-mile figure and the remaining 30.8 million acres receive none. The omission cannot be deferred to project-level review, because the DEIS's own statement of need rests on quantified national targets. At p. 79 the DEIS relies on Executive Order 14225 and on the One Big Beautiful Bill Act section 50301, which "directs the Forest Service to sell at least 250 million board feet more each year for the next 10 years," and on the National Active Forest Management Strategy's goal of "an increase in timber production nationally by 25 percent." At p. 40 the DEIS says the amounts and locations are uncertain because "the rulemaking would not compel, require, or authorize any sitespecific activities." Both positions cannot hold. If the rescission is needed to meet a quantified national harvest target, then the harvest and the road construction required to reach that target are reasonably foreseeable effects of the rescission, and 42 U.S.C. 4332(2)(C) requires "a detailed statement... on... reasonably foreseeable environmental effects of the proposed agency action." If they are not reasonably foreseeable, the stated need for the rescission is unsupported, and every alternative eliminated for failing to meet that purpose was eliminated against a purpose the agency has not substantiated. The Forest Service should supplement analysis under 7 CFR 1b.7(f)(2)(iii) with a quantified, regionally stratified projection of road-mile construction and resulting sedimentation and fragmentation across the potentially affected environment under each action alternative, at the level of specificity the DEIS applied to the Tongass National Forest at pp. 238-239, and cite in the final EIS where that supplemented analysis is accounted for, as 7 CFR 1b.7(f)(3) provides.