Comment Analysis · Docket FS-2025-0001

FS-2025-0001-606634

Opposes rescissionA0 noneSubstance 6/24Posted October 7, 2026 On Regulations.gov

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

A0 none: Counted, not answered.

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.
  • Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
  • 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.
  • 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.

Topics

  • Environmental Protection Biodiversity
    • “critical fish and wildlife habitats including habitats for threatened and endangered species”
    • “spectacular roadless areas such as Rugged Ridge, Lower Gray wolf, Middle Dungeness”
    • “buffer existing wilderness areas, Buckhorn, The Brothers, Mt. Skokomish”
  • Water Quality Quantity
    • “provide clean air, clean water”
    • “protection to upper and middle watersheds including domestic water supplies”
  • Climate Carbon Storage
    • “important and necessary carbon storage”
    • “critical carbon storage”
  • Recreation Tourism Public Use
    • “hiked, gathered firewood and enjoyed nature”
    • “recreation opportunities for present and future generations”

What it names

National Forests
Olympic National Forest
Roadless areas
Jupiter RidgeRugged RidgeSouth ForkSouth Quinault

The comment

I strongly object to the U.S. Forest Service proposal to rescind the 2001 Roadless Area Conservation Rule. The Roadless Rule wisely blocks roadbuilding, logging, drilling, and mining on 45 million acres of national forests, about a third of our national forest system. This is critical because these lands provide clean air, clean water, important and necessary carbon storage, and critical fish and wildlife habitats including habitats for threatened and endangered species. In Olympic National Forest, where I have worked, hiked, gathered firewood and enjoyed nature, spectacular roadless areas such as Rugged Ridge, Lower Gray wolf, Middle Dungeness, Jupiter Ridge, Lena Lake, South Fork Skokomish and South Quinault Ridge are all well deserving of Roadless Area designation. All of these areas offer protection to upper and middle watersheds including domestic water supplies. All buffer existing wilderness areas, Buckhorn, The Brothers, Mt. Skokomish, Wonder Mountain, and Colonel Bob wildernesses and nearby Olympic National Park, a UNESCO Biosphere Reserve and World Heritage site. And nearly all are included in U.S. Senator Murray's and U.S. Representative Emily Randall’s Wild Olympics Wilderness and Wild and Scenic Rivers Act, currently being considered by Congress. Roadless areas contain less than a quarter of one percent of the nation’s timber and an even smaller fraction of oil and gas reserves. They are more fire resistant than roaded areas, where the majority of fires occur. However this proposal would throw them open to road building and polluting extractive industries for private profit at the public’s expense. The Forest Service's EIS for this project is wholly inadequate and fails to consider the environmental and economic benefits roadless areas provide or the costs incurred in rescinding roadless rule protections. These lands are much more valuable for the public benefits they provide: clean air, clean water, critical carbon storage, fish and wildlife habitats and recreation opportunities for present and future generations than for the meagre and fleeting benefits to be gained by developing them. I endorse the arguments included in Washington Wild's comment letter, which was signed my multiple parties including Olympic Park Advocates, of which I am a long-time member.

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