Comment Analysis · Docket FS-2025-0001

FS-2025-0001-608881

Opposes rescissionA1 strongSubstance 17/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents that the agency's draft environmental impact statement contains internal contradictions regarding wildlife survival, wildfire ignition rates, and economic net benefits, and requests that the agency reconcile these findings and apply cited biodiversity fragmentation data to the full scope of affected acres before finalizing 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

A1 strong: Must be answered — it names the law.

Owed an answer on Analytical gap, Evidence, 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

Wildlife Habitat
- “elk avoid areas near roads and select habitat away from them”
- “increased contact, conflict, and mortality risk for bears”
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
Forest Management Wildfire
- “Additional roads only increase the odds of human-caused fires”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “reconcile the rescission with the ignition data in its own draft environmental impact statement”
Water Quality Quantity
- “Roads degrade watersheds”
- “Washington alone holds 1,522 municipal water intakes in watersheds containing affected roadless areas”
Economic Impact Fiscal
- “recreation losses of at least $6.1 million a year”
- “net present value spanning -$92 million to +$199 million”
- “expanding a road system already carrying a $6.9 billion maintenance backlog”

What it names

National Forests: Gifford Pinchot National Forest
Law cited: 36 C.F.R. Section 294.12

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 Nearly 80 years old and I have never seen a northern spotted owl, a black bear, or an elk. I have not stopped looking. They are out there in the 213,000 roadless acres of the Gifford Pinchot National Forest, 15 miles away. I have lived in the Pacific Northwest all my life. This has been and will always be my home. I oppose the rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001, and I ask that this comment be entered into the record. The elk I have spent years looking for depend on that unroaded country. The agency's own record shows that elk avoid areas near roads and select habitat away from them, and that elk survival rates rose during a road closure and fell again when the gates were removed. Every mile of new road pushed into the Gifford Pinchot is habitat the elk abandon. The same record ties open roads to increased contact, conflict, and mortality risk for bears. I have not yet seen a black bear in that forest. Rescission makes it less likely anyone will. I ask the agency to explain how this outcome is consistent with its own wildlife findings, and to specify what road-avoidance data it weighed before concluding that expanded road access serves the animals living inside these areas. Every summer is now a fire season in the Pacific Northwest. The air becomes dangerous to breathe for both humans and wildlife, and the areas coming under evacuation orders keep coming closer. Additional roads only increase the odds of human-caused fires. The agency's own language confirms exactly this: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal claims wildfire management as a justification for rescission. That justification and this finding cannot both be true at once. I ask that the agency explain on the record why the proposal departs from its own prior findings on fire occurrence, and that it reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. Roads degrade watersheds. Washington alone holds 1,522 municipal water intakes in watersheds containing affected roadless areas. . The agency does not have the funding to manage the roads it already has. It makes no sense to add roads it cannot maintain. The agency's own record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." A fraction of a percent of national production does not justify expanding a road system already carrying a $6.9 billion maintenance backlog. I ask that the agency reconcile the proposal with its own economic analysis, which projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million, and that it explain how an action whose own cost-benefit analysis cannot establish a net benefit is justified. The rule as it stands already allows the agency to act where it must. It states that it "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." The agency has not shown which specific burdens fall outside those exceptions. I ask that it identify them, quantify them, and show the record behind that accounting. The agency's own DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. Washington holds 139 inventoried roadless areas totaling 2,014,832 acres, part of the 40.1 million acres of potentially affected environment. That fragmentation range is cited and then set aside, never applied to the full scope of what is at stake. I ask that the agency apply the cited fragmentation range to the 40.1 million acres of potentially affected environment and enter that analysis into the record before any final decision is made. Old growth forests will not grow back in one lifetime. The roads that allowed access to removing them will remain as scars. The Gifford Pinchot held more than 600 public meetings and took 1.6 million comments to build the rule that protects these places. Losing the Gifford Pinchot to logging, mining, additional grazing, and harmful motorized use would be one of the greatest sorrows of my life. The generations to come should not have less to inherit. Sincerely, Kathryn Edgecomb Vancouver, Washington