Comment Analysis · Docket FS-2025-0001

FS-2025-0001-608259

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

In short: The comment establishes that the agency's justification for rescinding the Roadless Rule based on wildfire risk is contradicted by data showing low ignition rates in roadless areas, and documents the specific ecological, water quality, and climate benefits of maintaining the rule under Alternative 1.

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

Wildlife Habitat
- “adversely affect 327 threatened and endangered species”
- “vital habitat for threatened species”
- “Bull trout, Chinook salmon, Chum salmon, Coho salmon”
- “Marbled murrelet, Northern spotted owl”
Water Quality Quantity
- “safeguards clean drinking water for millions of Americans”
- “threaten our water supplies”
- “road construction and native surface forest roads are the largest source of sediment”
- “sediment delivered to surface waters is a major source of water quality degradation”
Climate Carbon Storage
- “sustains old-growth and mature forests that serve as critical carbon sinks”
- “release of carbon stored in forest biomass and soils”
- “increase protections of our best carbon sinks”
- “draw down the dangerous excess of CO2 in our atmosphere”
Forest Management Wildfire
- “only 3% of all mapped historical wildfire ignition points... occurred within Roadless Rule areas”
- “roadless areas burned at a slightly LOWER rate than forests with roads”
- “increased susceptibility of thinned stands to fire spread”
- “Thinning requires an extensive road network that alters hydrology”

What it names

National Forests: Mt Baker-Snoqualmie National Forest

Attachments

1 file. Counts as 1 — Counts as one: The attachments enclose no one else's submissions; the comment counts as one.

Own letter

The comment

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

My name is Susan Fedore and I'm a lifelong resident of Washington state and have hiked, biked, skied, and explored many of our native natural forests including those along the North Nooksack River and in the Mt Baker Wilderness and Mt Baker-Snoqualmie National Forest. I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule and am in full support of Alternative 1. By the Trump administration's own admission, rescinding the roadless rule would result in lost recreation and visitor spending, threaten our water supplies, undermine tribal interests, spread invasive species, and imperil wildlife. Yet US Forest Service Chief Tom Schultz claims that active forest management of these "unroaded" public lands is essential because more than 40 percent had “high or very high wildfire hazard potential” and just 5 percent of that ground had seen fuels-reduction projects the past dozen years, stating, “acting now, thoughtfully and decisively, is the best way to restore the balance, reduce wildfire risk, and secure the long-term health of our forests and neighboring communities." In reality, data from the National Interagency Fire Center found that only 3% of all mapped historical wildfire ignition points over the last 50 years have occurred within Roadless Rule areas. Research has found that roughly 90% of all wildfires [https://www.pacificbio.org/publications/wildfire_studies/Roads_And_Wildfires_2007.pdf, see page 4] start within a half-mile of a road, and that 88% are human-caused — with roads acting as corridors for human error, including accidental sparks, unattended campfires, and other ignition sources that can spark blazes [https://www.nifc.gov/fire-information/fire-prevention-education-mitigation/wildfire-investigation]. A separate analysis of four decades of satellite data found that inventoried roadless areas have not burned at significantly higher rates or severity than "roaded" national forest lands, and that in the most recent decade, roadless areas burned at a slightly LOWER rate than forests with roads. Further, it has been well-researched and documented by internationally renowned forest ecologists that "there are substantial costs to ecosystems associated with large-scale forest removals from mechanical thinning. Depending on environmental context, scale, frequency, and type of removals, impacts include: (1) loss of ecological integrity in a key successional stage and degradation of habitat suitability for associated taxa; (2) increased susceptibility of thinned stands to fire spread from higher sub-canopy wind speeds and increased fine fuels (slash); (3) soil compaction from heavy machinery; (4) reduced resilience where thinning from above removes naturally competitive dominant trees that may contain adaptive gene complexes; (5) release of carbon stored in forest biomass and soils; and (6) an increase in flammable understory species, including the spread of invasive plants. Thinning requires an extensive road network that alters hydrology, especially where roads intersect streams and on steep erosive slopes. In addition, the relatively high financial costs of thinning may divert resources from other activities that are more cost-effective and restorative." Source: https://9a8e4068-0d04-454c-b575-a7a5de8f6dfa.usrfiles.com/ugd/9a8e40_9f43e4dd675d48a6a4b1e2f63caf2edb.pdf The Roadless Rule safeguards clean drinking water for millions of Americans. According to the DEIS, inventoried roadless areas typically have good water quality due to LIMITED disturbance,” noting “road construction and native surface forest roads are the largest source of sediment related to timber harvest operations, and sediment delivered to surface waters is a major source of water quality degradation.” The Roadless Rule provides vital habitat for threatened species. Eliminating the Roadless Rule would “adversely affect” 327 threatened and endangered species and 71 designated critical habitats for these species. The list includes species such as Bull trout, Chinook salmon, Chum salmon, Coho salmon, Marbled murrelet, Northern spotted owl, Oregon silverspot butterfly, Oregon spotted frog, Sierra Nevada red fox, and steelhead, among others. The Roadless Rule sustains old-growth and mature forests that serve as critical carbon sinks. Chad Hanson, co-founder of the John Muir Project and principle ecologist, has noted at this stage it is not possible to overcome the most severe upcoming impacts of the climate crisis solely by shifting away from consumption of fossil fuels. We must also, with equal vigor, increase protections of our best carbon sinks, especially our structurally complex and old-growth forests, to draw down the dangerous excess of CO2 in our atmosphere. For all reasons stated above, I strongly support keeping the Roadless Rule intact to protect our country's legacy of public lands by following Alternative 1 (No Action).