Comment Analysis · Docket FS-2025-0001

FS-2025-0001-225650

Opposes rescissionA2 moderateSubstance 15/24Owed an answerPosted August 20, 2026 On Regulations.gov

In short: The comment places on the record specific site-specific deficiencies in the agency's analysis, including a contradiction in the small-business certification, an unassessed reliance interest, a failure to quantify increased wildfire risk from road access despite internal data, an out-of-scope treatment of foreseeable plan amendments, and a failure to apply cited habitat fragmentation statistics to the affected acreage.

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

Environmental Protection Biodiversity
- “incredible biological diversity”
- “completely devoid of life the clear-cut areas are”
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
- “retain the 2001 rule's protections”
Water Quality Quantity
- “local water supply originates in the Mt. Hood forests”
- “purity is protected by the limited traffic”
- “drinking-water sources”
Forest Management Wildfire
- “Human-caused ignition density is 22.4 fires per million acres”
- “human-caused ignitions increase in abundance with proximity to roads”
- “road access could increase the number and frequency of wildfires”
- “quantify the expected increase in human-caused ignitions”
Legal Regulatory Framework
- “small-business certification contradicts the analysis”
- “reliance interests are invited and never assessed”
- “Encino Motorcars and Regents”
- “foreseeable plan amendments are placed beyond scope”

What it names

National Forests: Gifford Pinchot National Forest Gifford Pinchot National Forest Mt. Hood National Forest Mt. Hood National Forest
Roadless areas: Salmon - HuckleberrySilver Star

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapEvidenceLegal

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I hike and camp in Mt. Hood National Forest and Gifford Pinchot National Forest. I observe and photograph the incredible biological diversity in these forests, and have seen how completely devoid of life the clear-cut areas are. Our local water supply originates in the Mt. Hood forests and its purity is protected by the limited traffic in those areas. You have no right to deprive my children and grandchildren of the opportunity to learn from and be nurtured by these rich wilderness areas. I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule, and specifically about these inventoried roadless areas: - Silver Star (7,779 acres), Gifford Pinchot NF, Washington - Salmon - Huckleberry (17,570 acres), Mt. Hood NF, Oregon I ask that the agency disclose and analyze the site-specific environmental consequences of the proposed rescission for each of these areas, including the effects of the road construction and timber harvest it would newly allow. I raise the following issues for the record and ask that the agency respond to each of them: Issue 1: The small-business certification contradicts the analysis beside it 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 regulatory flexibility analysis reaches its no-impact conclusion by spreading the $9 million annual expenditure loss across every small firm in the sector nationally, rather than assessing the outfitters and guides actually holding permits in the affected areas, and concedes some firms may lose these receipts. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. Issue 2: Reliance interests are invited and never assessed 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. Under Encino Motorcars and Regents, an agency changing course must assess the reliance interests its prior policy created. This comment is such an interest. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one. Issue 3: The agency’s own fire data cuts against the proposal 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. The effects analysis itself concedes that road access could increase the number and frequency of wildfires. I ask that the agency quantify the expected increase in human-caused ignitions from new road access and weigh it against the claimed reduction in wildfire hazard. Issue 4: Foreseeable plan amendments are placed beyond scope The proposed rule concedes that subsequent land management plan amendments and revisions “could increase the area where timber harvest and road construction would be allowed,” declares changes to plans beyond the scope of the proposal, and then requests public comment on them (91 FR 53830). The agency is asking commenters to perform the analysis it declared out of scope. I ask that the agency analyse the foreseeable plan-amendment scenario, including expanded timber harvest area, as part of this action. Issue 5: Fragmentation is quantified and not applied The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. The number appears; no projection across the 40.1 million affected acres follows. I ask that the agency apply the cited fragmentation range to the 40.1 million acres of potentially affected environment. I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule’s protections for the areas named above. Where this proposal rests on factual conclusions that differ from the agency’s own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record. Sincerely, Michael D Metzler, MD, PhD The Dalles, Oregon