Comment Analysis · Docket FS-2025-0001

FS-2025-0001-604712

Opposes rescissionA2 moderateSubstance 12/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment establishes that the proposal to rescind the Roadless Area Conservation Rule is internally inconsistent with the agency's own data on wildfire ignition rates (DEIS Table 21), economic costs (CBA and maintenance backlog), and water quality impacts (DEIS Table 35), and requests the agency reconcile these contradictions or withdraw the proposal.

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, 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.
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

Forest Management Wildfire
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “Routing roads through terrain like this... would not reduce fire risk. It would increase it.”
- “reconcile the rescission with the ignition data in its own draft environmental impact statement”
Water Quality Quantity
- “Washington's 1,522 municipal water intakes sitting in watersheds containing affected roadless areas”
- “roads and their facilities can produce up to 90 percent of the sediment from a timber sale”
- “fewer than 12 percent of the watersheds fed by roadless areas have impaired streams today”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “recreation losses of at least $6.1 million per year and a net present value ranging from negative $92 million to positive $199 million”
- “road system the proposal would expand already carries a $6.9 billion maintenance backlog”
Legal Regulatory Framework
- “Ninth Circuit has already reviewed what happens when the agency substitutes local decision-making for national protection”
- “Tenth Circuit's holding that the 2001 rule was within the authority Congress granted under the Organic Act”
- “explain how this proposal avoids the same deficiencies the court identified then”

What it names

National Forests: Olympic National Forest
Roadless areas: South QuinaultUpper Skokomish

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 forests I hike and camp in, across Washington, California, and many other states, belong to all of us and to our children. The proposal to rescind the 2001 Roadless Area Conservation Rule would betray both. I am filing this comment in opposition to Docket FS-2025-0001. The agency's own findings on wildfire make the rescission's logic collapse on itself. The record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal nonetheless uses wildfire and fuels management as a justification for opening roadless areas to new roads. Areas like the Upper Skokomish, 9,311 acres inside Olympic National Forest in Washington, and South Quinault, 11,081 acres in the same forest, sit within the 2,014,832 acres of inventoried roadless land Washington holds across 139 areas. Routing roads through terrain like this, terrain the agency's own data says carries far lower human-ignition density than roaded land, would not reduce fire risk. It would increase it. I ask that the agency explain in this proceeding why the proposal departs from its own prior findings, and reconcile the rescission with the ignition data in its own draft environmental impact statement, specifically DEIS Table 21, which documents the contrast between fire occurrence on roaded and unroaded land. The economic case for rescission is similarly unsupported by the agency's own numbers. The record acknowledges: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against that marginal supply figure, the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million per year, set against recreation losses of at least $6.1 million per year and a net present value ranging from negative $92 million to positive $199 million, a range so wide it cannot establish that any net benefit exists. Meanwhile the road system the proposal would expand already carries a $6.9 billion maintenance backlog. The agency must reconcile the proposal with those numbers and explain how an action whose own analysis cannot confirm a positive return justifies adding infrastructure costs to a system already in deficit. The proposal also argues that state-by-state approaches can replace a single national rule. But the agency's own record recalls "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The Ninth Circuit has already reviewed what happens when the agency substitutes local decision-making for national protection of roadless values: it found that approach legally deficient. Washington's 1,522 municipal water intakes sitting in watersheds containing affected roadless areas, a figure drawn from DEIS Table 35, cannot be protected piecemeal. The agency must explain how this proposal avoids the same deficiencies the court identified then. It is incredibly disturbing that we would consider taking this away, particularly the water protections these areas provide. The agency's own analysis found that roads and their facilities can produce up to 90 percent of the sediment from a timber sale, and fewer than 12 percent of the watersheds fed by roadless areas have impaired streams today. Those two facts together are a reason to hold the rule, not discard it. The agency must address the Tenth Circuit's holding that the 2001 rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness, and it must state clearly the legal basis for any position to the contrary. Public land managed for all people and for our children cannot absorb the costs this rescission would impose on water quality, fire safety, fiscal integrity, and settled law. I urge the agency to withdraw the proposal. Sincerely, Erika Francks