Comment Analysis · Docket FS-2025-0001

FS-2025-0001-603646

Opposes rescissionA3 weakSubstance 8/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents specific wildfire data for the Tongass National Forest (five fires, 0.6 acres in 2025) and cites Wilderness Society research to refute the wildfire justification for rescinding the Roadless Rule in the Tongass and Chugach national forests.

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 Evidence.

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
- “Providing critical watershed and clean water supply”
- “increasingly drought-stricken West”
- “clean water supply to an increasingly drought-stricken West”
Wildlife Habitat
- “Offer essential habitat for wildlife, fish and plants”
- “shrinking, fragmented and climate-shifting habitats”
- “refuges them to retreat to, and migrate across”
Recreation Tourism Public Use
- “Give important recreational opportunities”
- “vital escape from civilization”
- “hikers, bikers, campers, horse riders, hunters and fishermen”
Forest Management Wildfire
- “wildfires are less likely to ignite in roadless forested areas”
- “Wildfire risk does not justify removing protection”
- “Tongass recorded only five wildfires totaling approximately 0.6 acres in 2025”

What it names

National Forests: Wenatchee National Forest

The comment

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

I strongly oppose the proposal to rescind the 2001 Roadless Rule (the Rule) and wholesale open about 45 million acres of national forest roadless areas to logging, mining, drilling, roadbuilding and other development – without more careful consideration of the great value each area provides to Americans, such as: A)Providing critical watershed and clean water supply to an increasingly drought-stricken West and other parts of the country. B)Offer essential habitat for wildlife, fish and plants that suffer from shrinking, fragmented and climate-shifting habitats. The roadless areas provide refuges them to retreat to, and migrate across, as their habitats shrink or shift. C)Give important recreational opportunities -- and a vital escape from civilization -- for hikers, bikers, campers, horse riders, hunters and fishermen. These contributions, which have enormous economic value to nearby communities and the whole nation, are usually irrevocably lost when the roadless areas are developed. Finally, a main justification for rescinding the Rule is wildfire risk. There are two flaws in that justification: 1) Research cited by the Wilderness Society shows that wildfires are less likely to ignite in roadless forested areas vs. areas with roads; and 2) Wildfire risk does not justify removing protection for some of the most pristine, fish & wildlife rich, and spectacular roadless areas - the approximately 14.7 M acres of roadless areas in the Tongass and Chugach national forests —roughly one-third of area protected under the Rule. With their maritime climates, these forests tend to have a dramatically lower fire risk, e.g., the Tongass recorded only five wildfires totaling approximately 0.6 acres in 2025. Thus, I urge the Administration to reconsider rescinding the Rule. My opinion is based on: 1) my experience as a citizen involved in national forest planning going back to the mid-1980s; 2) my experience as a volunteer wilderness ranger in Wenatchee National Forest; and 3) My visits to scores of national forests around the country and several of the affected roadless areas.