Comment Analysis · Docket FS-2025-0001

FS-2025-0001-607304

Opposes rescissionA2 moderateSubstance 14/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents specific deficiencies in the agency's analysis regarding road maintenance funding, wildfire ignition density, small business impact averaging, and the failure to weigh reliance interests, while citing specific data from the DEIS and FR notices to support a request to withdraw the proposed rescission of the 2001 Roadless Area Conservation 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

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

Recreation Tourism Public Use
- “connect with friends, family, and nature”
- “hiking and camping across Washington”
- “foundation of that experience”
- “organized my outdoor life in Washington around the existence of roadless protections”
Forest Management Wildfire
- “Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas”
- “human-caused ignitions increase in abundance with proximity to roads”
- “safer from human-caused fire precisely because they are roadless”
- “quantify the expected increase in human-caused ignitions that would follow from new road access”
Governance Policy Process
- “The agency should deny this rescission”
- “Any change of this magnitude requires an expansive public process, not a quiet reversal”
- “The agency must identify and weigh the reliance interests described in the comments”
- “withdraw the small-business certification and conduct a genuine assessment”
Economic Impact Fiscal
- “Road appropriations fell from $234 million in 2004 to $73 million in 2024”
- “deferred maintenance backlog of $6.9 billion for roads and bridges”
- “books lost recreation benefit at a minimum of $6.1 million a year”
- “name the specific funding source for any new road construction and maintenance”

What it names

National Forests: Olympic National Forest
Roadless areas: Eagle RockGreen MountainJefferson RidgeJupiter RidgeMt. Zion
Works cited: Furniss et al. 1991

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 national forests of Washington State are where I go to connect with friends, family, and nature. Hiking and camping across Washington is, as I think of it, a home for my soul, and the roadless areas that make that possible, places like Eagle Rock in the Mt. Baker-Snoqualmie, and Green Mountain, Jupiter Ridge, Mt. Zion, Quilcene, Jefferson Ridge, and the other inventoried roadless lands of the Olympic National Forest, are the foundation of that experience. Washington holds 139 inventoried roadless areas totaling 2,014,832 acres. I am asking this agency to leave them intact and to withdraw the proposed rescission of the 2001 Roadless Area Conservation Rule. Washington already has a great deal of working forest land, land that grows trees for industry and is accessible by road. We do not need more land converted to that condition by opening roadless country to new construction. The right approach is to maintain and make the best use of the lands with roads that already exist. No need to build more forest roads. The agency's own data makes the maintenance argument for me: "Road appropriations fell from $234 million in 2004 to $73 million in 2024, against a deferred maintenance backlog of $6.9 billion for roads and bridges, with supplemental funding expiring." Building new roads into country that currently has none, while that backlog sits unaddressed and the budget to address it has shrunk by so much, is not a coherent plan. I ask that the agency name the specific funding source for any new road construction and maintenance that rescission would enable, and state in the record the projected change in the deferred maintenance backlog that would result. The fire calculus in the agency's own analysis points in the same direction. "Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads." The Eagle Rock area, the Olympic roadless units, and the other places where I hike and camp are safer from human-caused fire precisely because they are roadless. The agency must quantify the expected increase in human-caused ignitions that would follow from new road access in these areas and weigh that increase honestly against any claimed reduction in wildfire hazard before this proposal advances. The economic accounting in the supporting documents does not hold together. "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." The flexibility analysis reaches its no-impact conclusion by spreading losses across every small firm in the sector nationally, rather than looking at the outfitters and guides who actually hold permits in the affected areas, and then concedes some of those firms may lose these receipts anyway. That is not a finding of no significant impact; it is an averaging away of a real impact on specific people. The agency should withdraw the small-business certification and conduct a genuine assessment focused on the small entities actually operating in the potentially affected roadless areas. This comment is itself a reliance interest of the kind the agency invited and then declined to weigh. "The proposal solicits 'any reliance interests in the current rule that could be affected by this proposal' (91 FR 53830-31), and the Cost Benefit Analysis weighs none." I have organized my outdoor life in Washington around the existence of roadless protections. Across the Pacific Northwest region, 1,522 municipal water intakes sit in watersheds containing affected roadless areas, and countless people beyond me have made similar choices premised on these protections remaining in place. The agency must identify and weigh the reliance interests described in the comments it receives, including the one expressed here, before it can lawfully change course. These are public lands. The Forest Service held more than 600 public meetings and received 1.6 million comments to write the rule that protects them. It has held none to undo it. Any change of this magnitude requires an expansive public process, not a quiet reversal. The agency should deny this rescission. Arvia Morris Seattle, Wa.