Comment Analysis · Docket FS-2025-0001

FS-2025-0001-607043

Opposes rescissionA1 strongSubstance 14/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents that the DEIS identifies specific water quality and wildlife risks (sediment, road maintenance, grizzly conflict) and quantifies economic losses ($6.1M/year) but fails to provide enforceable regulatory replacements for 36 CFR 294.12/294.13, quantify sediment delivery to intakes, or justify the rejection of Alternative 3, while incorrectly certifying no significant impact on small entities.

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, 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

Water Quality Quantity
- “strongest argument against this rescission is drinking water”
- “1,522 municipal water intakes sit in watersheds containing affected roadless areas”
- “skid roads, trails, log landings and similar disturbances within timber sale areas are the main cause of soil erosion”
- “Lack of maintenance commonly has detrimental effects on water quality”
Wildlife Habitat
- “Mountain goats, brown bears, and deer are treats to see, but their homeland is being disrupted”
- “retain protections for big game habitat, wildlife connectivity, and fisheries”
- “increased contact and conflict that come with open roads in grizzly habitat can ultimately end in grizzly mortality”
- “shooting, habituation and food reward all increase with the use of even secondary unpaved roads”
Recreation Tourism Public Use
- “Hiking takes me away from road noise and into a wilderness that is blissful and magical”
- “I want my children to hear the sound of the woods without cars running through it”
- “lost recreation benefit at a minimum of $6.1 million a year”
- “outfitters, guides, and tour operators as affected”
Governance Policy Process
- “The agency offers no enforceable replacement for 36 CFR 294.12 and 294.13”
- “The Forest Service held more than 600 public meetings and took 1.6 million comments to write this rule. It held none to undo it.”
- “certifies no significant impact on small entities while the DEIS names outfitters, guides, and tour operators as affected”
- “Why did the agency reject Alternative 3”

What it names

Roadless areas: Mt. Baker West
Law cited: 36 CFR 294.12

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequestAlternativeLegal

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Hiking takes me away from road noise and into a wilderness that is blissful and magical, and I need it to stay that way. Washington holds 139 inventoried roadless areas covering 2,014,832 acres, and I have lived here my whole life with so much still left to see. I oppose the rescission of the 2001 Roadless Area Conservation Rule and ask the agency to enter this letter into the record for Docket FS-2025-0001. The strongest argument against this rescission is drinking water, and the agency's own numbers make it. The DEIS states: "Approximately 24 million people use water originating within the potentially affected roadless areas, through more than 7,000 municipal intakes, and less than 12 percent of these watersheds are currently impaired." Across the Pacific Northwest region alone, which includes Washington, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. Water is an increasingly precious commodity. Drinking water is a necessity of life. Yet the agency offers no enforceable replacement for 36 CFR 294.12 and 294.13, pointing instead to forest plans without naming a single provision that does equivalent work. I ask the agency to identify, forest by forest, which plan provisions stand in for those protections in municipal watersheds. The agency also quantifies the sediment threat and then walks away from it. The DEIS acknowledges that skid roads, trails, log landings and similar disturbances within timber sale areas are the main cause of soil erosion and "can contribute up to 90 percent of the sediment generated by timber sale activity." That number is in the document. What follows it is silence: no projection of how much of that sediment reaches the intakes downstream. The agency owes the public a quantified estimate of projected sediment delivery to the more than 7,000 municipal intakes below these areas. I want that projection before any final rule issues. The road maintenance problem makes this worse, not better. The DEIS concedes: "Lack of maintenance commonly has detrimental effects on water quality. Insufficient maintenance funding is a key reason for the lack of adequate road maintenance." The agency proposes to add road mileage in the same document where it admits it cannot maintain the roads it already has. I ask the agency to explain, with specifics, how it reconciles that contradiction. Mountain goats, brown bears, and deer are treats to see, but their homeland is being disrupted, and I notice them appearing in places they should not be before we start seeing less of them altogether. The area I care about includes Mt. Baker West, 25,390 acres inside Mt. Baker-Snoqualmie National Forest. The DEIS built Alternative 3 specifically because commenters asked the agency to retain protections for big game habitat, wildlife connectivity, and fisheries. The agency considered that alternative and chose the one that protects none of it. For bears especially, the DEIS draws on the federal grizzly recovery plan, which warns 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. Why did the agency reject Alternative 3, and what does it tell the public about how it weighed that evidence against its chosen course? The record needs an answer. The beauty of nature is something learned and honored in my life. I want my children to hear the sound of the woods without cars running through it, to see glaciers and wild places in all their undiluted glory. The Forest Service held more than 600 public meetings and took 1.6 million comments to write this rule. It held none to undo it. Meanwhile, the proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides, and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. That certification was reached by spreading expenditure loss across every small firm in the sector nationally, not the guides and outfitters actually permitted in these areas. The agency should withdraw that certification and assess the impact on the businesses that actually operate in the potentially affected roadless areas. A logged grove grows back. A road does not. I ask the agency to keep the Roadless Area Conservation Rule in place. Sincerely, Maddy Seattle, WA