Comment Analysis · Docket FS-2025-0001

FS-2025-0001-607726

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

In short: The comment documents specific recreational sites in the Okanogan-Wenatchee and Mount Baker-Snoqualmie National Forests and requests the Forest Service retain the 2001 Roadless Rule, citing personal recreation history, potential loss of access, wildfire risks, and the fiscal burden of maintaining 380,000 miles of existing roads.

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

  • Recreation Tourism Public Use
    • “loss of access, or increased costs and barriers to access”
    • “irreplaceable opportunities for recreation, solitude, and connection with wild places”
    • “degrade both the natural character and recreational value of these areas”
  • Environmental Protection Biodiversity
    • “expose more of these relatively untouched places to the same problems”
    • “alter the natural processes that make these canyons unique”
    • “irreversible damage to the places where I recreate”
  • Economic Impact Fiscal
    • “fiscally irresponsible to expand the active road network”
    • “limited resources”
    • “substantial challenges maintaining its existing road network”
  • Forest Management Wildfire
    • “potential for human-caused ignitions that roads can bring”
    • “fully explore and utilize those existing wildfire-management options”
    • “extreme seasonal flooding, unstable log jams”

What it names

National Forests
Wenatchee National Forest
Roadless areas
Liberty Bell

The comment

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

Roadless Areas contain some of the wild spaces that have shaped my experience with outdoor recreation, and I continue to recreate in these landscapes frequently today. For example, Liberty Bell in the Okanogan-Wenatchee National Forest is where I led my first multi-pitch trad climb, Hidden Creek in the Mount Baker-Snoqualmie National Forest was one of the first canyons I explored and helped inspire my love of public lands, and Mineral Creek in the Okanogan-Wenatchee National Forest is where I take new canyoners to experience the waterfalls and wild landscapes of Washington. These are only three examples of the dozens of ways I recreate in Roadless Areas. I am deeply concerned that rescinding the Roadless Rule could eventually result in the loss of access, or increased costs and barriers to access, as logging, road construction, and other extractive activities expand into currently Roadless Areas. I have already seen some of these impacts in canyons where logging leases have affected access and the surrounding landscape, and I worry that opening roads in Roadless Areas could lead to similar outcomes in other places where I recreate. I am also concerned about the effects of increased roads and human access on the condition of these areas. In canyons that are currently accessible by roads, canyoners already encounter excessive garbage dumping and invasive species. I worry that opening currently Roadless Areas to additional roads and development would expose more of these relatively untouched places to the same problems. Road construction also has the potential to alter the natural processes that make these canyons unique. In my experience, canyons near roads have experienced problems including extreme seasonal flooding, unstable log jams, and destruction of anchors used for technical canyon access. I am concerned that increasing road density could exacerbate these impacts and degrade both the natural character and recreational value of these areas. Wildfire risk is another significant concern for me. Multiple members of my family lost their homes in human-caused fires during the past fire season, making this issue particularly personal. I understand that the existing Roadless Rule allows for wildfire management within Roadless Areas. I would ask the Forest Service to fully explore and utilize those existing wildfire-management options rather than opening additional wild areas to roads and the increased human access and potential for human-caused ignitions that roads can bring. I also have a significant fiscal concern. The Forest Service is already responsible for maintaining approximately 380,000 miles of National Forest System roads, and the agency faces substantial challenges maintaining its existing road network. Many existing roads are aging or inadequately maintained because of limited resources. Given these constraints, I believe it would be fiscally irresponsible to expand the active road network into currently Roadless Areas when there are already so many existing roads that the Forest Service does not have the resources to adequately maintain. I urge the Forest Service to retain protections for Roadless Areas and not rescind the 2001 Roadless Rule. These landscapes provide irreplaceable opportunities for recreation, solitude, and connection with wild places. I fear that rescinding the Roadless Rule will lead to irreversible damage to the places where I recreate, permanently altering the landscapes that I feel incredibly fortunate to enjoy today. I hope future generations will have the same opportunity to experience these wild places as I have.

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