Comment Analysis · Docket FS-2025-0001

FS-2025-0001-605012

Opposes rescissionA1 strongSubstance 17/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment places on the record specific deficiencies in the agency's DEIS regarding grizzly bear mortality risks, wildfire ignition data (Table 21), water quality impacts on 1,522 municipal intakes, and economic inconsistencies, while citing Tenth Circuit precedent to challenge the legal basis for rescinding 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

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

Wildlife Habitat
- “roadless habitat is where wildlife has a genuine chance to recover”
- “increased contact and conflict that come with open roads in grizzly habitat can ultimately end in grizzly mortality”
- “Opening that network to roads puts grizzly recovery and many other species at direct risk”
Forest Management Wildfire
- “Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires”
- “More roads means more human-caused ignitions, more fires for already-stretched crews”
- “reconcile the rescission with the ignition data in its own DEIS Table 21”
Water Quality Quantity
- “water supply depends on intact forests holding snowpack and regulating flow”
- “roads and their facilities can produce up to 90 percent of the sediment from a timber sale”
- “introducing roads into currently intact watersheds is consistent with its water quality obligations”
Legal Regulatory Framework
- “Tenth Circuit has already spoken, holding... the 2001 rule within the authority Congress granted”
- “state plainly what legal basis supports a contrary position now”
- “what conflict-of-interest review was conducted before this proposal was advanced”

What it names

Law cited: 28 U.S.C. Section 1291

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 country my family has lived in for generations is disappearing. What my ancestors enjoyed, I think will vanish in my lifetime. Rescinding the 2001 Roadless Area Conservation Rule will accelerate that loss, and I oppose it without qualification. I visit the Selkirk grizzly bear recovery area in northeastern Washington and the many roadless areas in the central Washington Cascades because roadless habitat is where wildlife has a genuine chance to recover from the pervasive, negative impacts already pressing down on every ecosystem. Habitat loss and degradation is the primary driver of extinction and extirpation, and roadless designation is one of the few tools that allows habitats to recover ecosystem function and provide necessary refuge. The agency's own draft environmental impact statement draws directly on the federal grizzly recovery plan to note that the increased contact and conflict that come with open roads in grizzly habitat can ultimately end in grizzly mortality, and that shooting, habituation and food reward all increase with the use of even secondary unpaved roads. Washington alone holds 139 inventoried roadless areas totaling 2,014,832 acres. Opening that network to roads puts grizzly recovery and many other species at direct risk, and I ask the agency to explain what mitigation it proposes that would be more protective than the rule it is eliminating. I am a third-generation wildland firefighter. My family has watched fire behavior change to extremes we see today. The agency ignores its own science and firefighters when it justifies opening roadless areas on fire-management grounds. The agency's own 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." More roads means more human-caused ignitions, more fires for already-stretched crews, and more firefighters exposed to injury, long-term disability, and death. The agency must explain on the record why this proposal departs from its own prior findings on fire occurrence in roadless areas and reconcile the rescission with the ignition data in its own DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. Out west, we have snow driven hydrographs where water supply depends on intact forests holding snowpack and regulating flow across the year. Across the Pacific Northwest region, which includes Washington, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. The agency's own analysis establishes that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. The agency should explain how introducing roads into currently intact watersheds is consistent with its water quality obligations. The economics of this proposal do not hold together. The agency's own record states that "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." The agency's current reorganization plan justifies the closure of national forest offices and research facilities citing its facilities budget. Rescinding the rule would add road miles to a system already carrying a $6.9 billion maintenance backlog against a road budget of about $73 million a year. There is no transparency in how the administration is justifying additional expenditure while cutting costs everywhere else. The agency must reconcile the proposal with its own cost-benefit analysis and explain on the record how an action whose own numbers cannot establish a net benefit is consistent with responsible stewardship. On the question of statutory authority, the Tenth Circuit has already spoken, holding: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The agency should address that holding, which found the 2001 rule within the authority Congress granted and held that it did not create de facto wilderness, and state plainly what legal basis supports a contrary position now. Finally, a significant portion of the roadless areas in Washington are adjacent to industrial timber companies that would benefit enormously from rescission. Civilian public servants are held to high ethical standards. I ask the agency to address on the record what conflict-of-interest review was conducted before this proposal was advanced.