Comment Analysis · Docket FS-2025-0001

FS-2025-0001-612265

Opposes rescissionA2 moderateSubstance 12/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents specific contradictions between the agency's DEIS findings on wildfire risk, deer habitat, and economic costs versus the proposed rescission, citing specific locations in the Olympic National Forest and requesting explanations for these discrepancies.

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
- “deer migration routes”
- “recovery of deer populations”
- “old-growth winter shelter”
- “creatures using that unroaded country”
Water Quality Quantity
- “municipal water intakes”
- “sediment from a timber sale”
- “impaired streams”
- “protects it”
Forest Management Wildfire
- “human-caused wildland fire”
- “fire density on roaded land”
- “old forests are for fire prevention”
- “honest fire management goal”
Economic Impact Fiscal
- “total timber volume affected”
- “$6.9 billion behind on maintaining the roads”
- “Cost Benefit Analysis”
- “net benefit”

What it names

National Forests: Olympic National Forest
Roadless areas: Green MountainJefferson RidgeJupiter RidgeMt. ZionUpper Skokomish

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeEA analysisAnalytical gapEvidenceRequest

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The rivers and lakes of Washington are some of the greatest things I have ever experienced. I walk them for the beauty of nature, and I photograph everything I find, bugs and deer alike, because they all matter and they all play a part. I photograph them so that my future children and the people I love can see the importance of them all. These places and creatures shaped how I see the world, and the roadless areas of the Olympic National Forest, places like Jupiter Ridge, Jefferson Ridge, Green Mountain, Lightning, Upper Skokomish, and Mt. Zion, are the kind of country that makes all of it possible. I am opposed to rescinding the 2001 Roadless Area Conservation Rule. The wildfire rationale for this rescission contradicts the agency's own findings, and I want that contradiction addressed. The DEIS 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 been fortunate enough not to live through a fire season myself, but I know how important old forests are for fire prevention. When the agency's own data in DEIS Table 21 shows far higher fire density on roaded land than inside the affected roadless areas, the agency must explain on the record why the proposal departs from those findings and how opening these areas to roads serves any honest fire management goal. The deer I photograph and watch in these forests face a documented threat from new roads that the agency itself has identified. The DEIS cites research finding that roads built for extraction may have altered deer migration routes and increased their movement speed, and the agency's own Tribal record credits the rule's protections with the recovery of deer populations in Alaska by preserving old-growth winter shelter. Washington holds 2,014,832 acres across 139 inventoried roadless areas. Deer and every other creature using that unroaded country depend on it staying that way. I want the agency to explain what happens to those populations when that security is removed. The economics of this proposal do not hold together, and I want that explained too. 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." The agency is already $6.9 billion behind on maintaining the roads it has. They are stretching themselves too thin just to make people who do not understand the importance happy. The agency must reconcile the proposal with its own Cost Benefit Analysis, which cannot establish a net benefit, and explain how expanding a road system already carrying that maintenance backlog is justified by figures this small. Clean water is one of the most important things for people and animals alike, and the roadless rule protects it. Across the Pacific Northwest region, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. The agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Fewer than 12 percent of those watersheds have impaired streams today. That record needs to be weighed against this proposal, and I ask that the agency explain what specific protection replaces the rule for those watersheds. My future children should inherit more of these places than I did. I want us to find better ways to coexist with nature rather than bulldoze everything for parking lots and roads. Going the other direction will burn the world and take us all down with it. The Forest Service held more than 600 public meetings and took 1.6 million comments to write this rule. It has held none to undo it. That asymmetry alone demands a full and honest answer.