Comment Analysis · Docket FS-2025-0001

FS-2025-0001-593177

Opposes rescissionA3 weakSubstance 11/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment establishes that the draft EIS fails to reconcile wildfire ignition data with the rule's rationale, fails to quantify sediment impacts on specific watersheds in the Olympic and Mount Baker–Snoqualmie National Forests, and documents the commenter's request to select the No Action alternative to retain the 2001 Roadless Rule.

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

A3 weak: Substantive, but easier to set aside.

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.
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.
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.
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

Water Quality Quantity
- “source watersheds for a large share of the nation's drinking water”
- “Roads are the single largest source of sediment on Forest Service lands”
- “damage to water quality and fish habitat is not reversible”
- “Increasing sediment within these watersheds will have huge impacts on water quality”
Forest Management Wildfire
- “wildfire ignition density is highest within about 165 feet of roads”
- “Building roads into roadless areas introduces ignition sources”
- “The 2001 rule already permits fuel reduction and fire management”
- “Human-caused ignitions account for roughly 84 percent of wildfires”
Wildlife Habitat
- “provide cold-water habitat for threatened species, including bull trout”
- “bull trout... do not occur in watersheds with more than 1.7 miles of road per square mile”
- “animals that rely on these tributaries”
- “refuge for many Washingtonians”
Economic Impact Fiscal
- “Forest Service already carries a $6.9 billion deferred maintenance backlog”
- “cannot maintain the more than 386,000 miles of road it already has”
- “poor fiscal stewardship”
- “cost ultimately falls on taxpayers”

What it names

National Forests: Olympic National Forest
Roadless areas: Dark Divide

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeEA analysisAnalytical gapEvidenceRequestAlternative

I am submitting this comment in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule, and in support of the No Action alternative. The proposed rule's stated justification is wildfire prevention, but the evidence does not support it. The 2001 rule already permits fuel reduction and fire management through exceptions. More importantly, a 2026 assessment of ignition data from 1992 to 2024 across all eight contiguous Forest Service regions found that wildfire ignition density is highest within about 165 feet of roads and lowest in designated wilderness and inventoried roadless areas. Human-caused ignitions account for roughly 84 percent of wildfires nationally. Building roads into roadless areas introduces ignition sources into the lowest-ignition lands we have. The draft Environmental Impact Statement does not adequately reconcile this evidence with the claim that road building reduces fire risk, and I ask that it do so before any final decision. The rule's own analysis undercuts its rationale. It estimates that only about 4.8 million acres, 16 percent of forested roadless land, are operable for timber, and that full harvest, which it calls unlikely, would produce at most a 5 to 10 percent increase in sawtimber harvest. The agency itself describes the benefit as marginal, modest, and localized. It also anticipates no net change in oil, gas, and coal production. I do not believe a permanent change to the most intact forest lands in the National Forest System is justified by a benefit the agency concedes is this small. The costs, by contrast, are real and lasting. Roadless areas are the source watersheds for a large share of the nation's drinking water, supplying at least 25 million people according to a 2026 study in PLOS Water. They provide cold-water habitat for threatened species, including bull trout, which the Forest Service's own science shows do not occur in watersheds with more than 1.7 miles of road per square mile. Roads are the single largest source of sediment on Forest Service lands, and the damage to water quality and fish habitat is not reversible on any meaningful timescale. These are the reliance interests the proposed rule invited comment on, and they weigh heavily against rescission. The economics are also backwards. The Forest Service already carries a $6.9 billion deferred maintenance backlog for roads and bridges, and cannot maintain the more than 386,000 miles of road it already has. Authorizing new road construction on land it cannot afford to maintain is poor fiscal stewardship, and the cost ultimately falls on taxpayers. I am particularly concerned about the Olympic National Forest and Mount Baker–Snoqualmie National Forest, and the Dark Divide Roadless Area. The ONF and Mount Baker hold tributaries for some of Washington State's largest watersheds, including the Cowlitz, Soleduc, and Upper Skagit. Increasing sediment within these watersheds will have huge impacts on water quality, not just for humans, but also for the animals that rely on these tributaries. The sediment impact has not been fully addressed in this DEIS and needs to be quantified before making a decision. The Dark Divide is one of the largest unroaded areas left in Western Washington, removing the guardrails that currently keep new roads out is a decision that cannot be reversed. Once that area is opened up, the stillness that makes that place a refuge for many Washingtonians will be gone. This is the kind of place-specific harm the national prohibition currently prevents, and the draft EIS does not adequately analyze it. For these reasons, I urge the Department to retain the 2001 Roadless Rule by selecting the No Action alternative. Becky Dilba, Washington