Comment Analysis · Docket FS-2025-0001

FS-2025-0001-609740

Opposes rescissionA1 strongSubstance 13/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents that the agency's record contains internal contradictions regarding wildfire risk (citing DEIS Table 21) and water quality protection, and requests an explanation for how the rescission aligns with prior judicial holdings under the Organic Act and MUSYA.

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

Environmental Protection Biodiversity
- “we have done enough damage to natural habitats”
- “A logged stand can grow back over many lifetimes”
- “The Olympic Peninsula is magical because of the plants and animals”
- “no animals”
Forest Management Wildfire
- “Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence 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 DEIS Table 21”
- “far higher fire density on roaded land than inside the affected roadless areas”
Water Quality Quantity
- “1,034 municipal water intakes sitting in watersheds containing affected roadless areas”
- “clean, fresh-tasting drinking water was a privilege”
- “guards water quality in places like the Pacific Southwest”
- “It is a necessity everyone relies on multiple times every day”
Legal Regulatory Framework
- “The Tenth Circuit held: 'Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE'”
- “deficiencies the Ninth Circuit identified the last time it substituted local decision-making”
- “question courts have already resolved”
- “basis for any position contrary to the Tenth Circuit's holding”

What it names

National Forests: Olympic National Forest
Law cited: 28 U.S.C. Section 1291

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequestLegal

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Olympic Peninsula is where I take a deep breath and life doesn't feel as heavy. It is where my favorite childhood memories live, where I have been present with friends and family in some of the most beautiful places I know. Now that I am in college in California, it is what I think of as home, and I crave to go back. I am writing to oppose Docket FS-2025-0001 because rescinding the 2001 Roadless Area Conservation Rule would put the 86,000 acres of inventoried roadless area in Olympic National Forest, Washington, and places like it, at permanent risk, and because the agency's own record does not support what it is proposing to do. Driving around Washington this past summer, I kept seeing stumps where I had not seen them as a child. The land looked dead. There were no animals. It was distressing in a way I did not expect, and it confirmed something I already believed: we have done enough damage to natural habitats. We need to start protecting them, and that begins with the ecosystems and the land itself. A logged stand can grow back over many lifetimes, but I do not want children to inherit fewer of these places than I did, or to watch their parents drive through land they loved and find stumps where trees used to stand. A road, once built, does not grow back. If a road went into the Olympic roadless area, it would no longer hold the same peace it currently does, and that loss would be permanent in any meaningful human timeframe. The agency argues that rescission supports wildfire management, but its own record states: "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." I have lived through many fire seasons. I have seen plans canceled, seen those without somewhere to go struggle, felt the weight on my lungs going outside, and watched temperatures change dramatically. The agency must explain why this proposal departs from its own prior findings, and must reconcile the rescission with the ignition data in its own DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. I now live in California, a state that holds 381 inventoried roadless areas totaling 4,389,760 acres, with 1,034 municipal water intakes sitting in watersheds containing affected roadless areas. Growing up in Seattle, I did not fully understand that clean, fresh-tasting drinking water was a privilege until I left. It is not, and it should not be treated as one. It is a necessity everyone relies on multiple times every day, and the agency should address how replacing a single protective rule with a patchwork of state-by-state approaches guards water quality in places like the Pacific Southwest at anything like the same level. The record states that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The agency should explain how this proposal avoids the deficiencies the Ninth Circuit identified the last time it substituted local decision-making for the national rule, given its own prior finding that local approaches can incrementally reduce nationally significant roadless values. Finally, the proposal questions whether the 2001 rule was within the agency's statutory authority, a question courts have already resolved. The Tenth Circuit held: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The agency owes a direct explanation of the basis for any position contrary to the Tenth Circuit's holding that the 2001 rule fell within authority Congress granted under the Organic Act and MUSYA and did not create de facto wilderness. The Olympic Peninsula is magical because of the plants and animals and the unbroken land that makes it what it is. I want to protect it, and I want the agency to answer these questions squarely before proceeding any further. Sincerely, Rosalee Meyer Seattle, Washington