Comment Analysis · Docket FS-2025-0001

FS-2025-0001-608450

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

In short: The comment documents that the agency's DEIS and Cost Benefit Analysis fail to account for the increased human-caused fire risk, the specific reliance interests of local water intakes and outfitters, and the economic impacts on small entities in the affected areas, while citing specific data on fire density and funding shortfalls to support the request to reconsider the rescission.

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
- “explore them”
- “experience nature as it is”
- “next generation can do the same”
- “fewer wild places”
Water Quality Quantity
- “1,522 municipal water intakes”
- “watersheds containing affected roadless areas”
- “families who depend on those intakes”
- “assumption that these watersheds remain protected”
Forest Management Wildfire
- “Human-caused ignition density is 22.4 fires per million acres”
- “human-caused ignitions increase in abundance with proximity to roads”
- “quantify the expected increase in human-caused ignitions”
- “undercuts the case for opening these areas”
Economic Impact Fiscal
- “tax dollars spent protecting and maintaining”
- “deferred maintenance backlog of $6.9 billion”
- “name the funding source for new road construction”
- “lost recreation benefit at a minimum of $6.1 million a year”

What it names

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 Public lands in Washington belong to my son as much as they do to anyone alive today, and I want him to be able to explore them. That is what brings me to this comment opposing the rescission of the 2001 Roadless Area Conservation Rule. Washington holds 139 inventoried roadless areas totaling 2,014,832 acres. These are places where my family can still experience nature as it is, and where the next generation can do the same. A logged stand grows back. The agency itself has acknowledged that roads do not. The Forest Service held more than 600 public meetings and took 1.6 million comments to write the rule protecting these areas. It has held none to undo it. Trees help clean the air, and anything we can do to protect air quality should be prioritized, not traded away. Our next generation will face plenty of challenges without inheriting fewer wild places and dirtier air than we had. On the question of roads and money: I want my tax dollars spent protecting and maintaining what already exists. The agency's own figures show that 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. The DEIS states that road mileage, deferred maintenance and management costs are likely to increase under this proposal. Before rescinding a rule that has kept these areas intact, the agency must name the funding source for new road construction and maintenance and state, in plain terms, the projected change in that backlog. The agency's own fire data undercuts the case for opening these areas. "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." Any claimed reduction in wildfire hazard from new access must be weighed against that reality. I ask that the agency quantify the expected increase in human-caused ignitions from new road access and show its work. Across the Pacific Northwest region, which includes Washington, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. The families who depend on those intakes have organized their lives around the assumption that these watersheds remain protected. So have the outfitters, guides and tour operators who hold permits in these forests. "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." That is not a minor omission. This comment is itself a reliance interest: a parent who has built expectations about what his son will be able to experience. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before it proceeds. The regulatory flexibility analysis compounds the problem. "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 supporting analysis reaches its no-impact conclusion by spreading losses across every small firm in the sector nationally rather than looking at the businesses actually permitted in the affected areas. The agency should withdraw that certification and do the analysis it skipped, focused on the small entities that actually operate in these places, not a national average. Any action that moves toward privatizing or degrading the lands the next generation has to experience nature reduces what they inherit. I ask that the agency answer each of these points in the record and reconsider this rescission. Sincerely, Lauren Moussa Seattle, Washington