Comment Analysis · Docket FS-2025-0001

FS-2025-0001-274797

Opposes rescissionA2 moderateSubstance 12/24Owed an answerPosted August 27, 2026 On Regulations.gov

In short: The comment establishes that the agency's Draft Environmental Impact Statement and Cost Benefit Analysis contain internal contradictions regarding wildfire risk, ecological impacts on birds, and net economic benefits, and documents specific reliance interests in the Umpqua National Forest that the agency has failed to weigh in its proposal to rescind the Roadless Area Conservation Rule.

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.

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
- “photograph fungi, insects, native plants, and birds”
- “birds I watch along the Umpqua depend on intact forest structure”
- “bird richness declines with road presence”
- “31 percent of species avoiding the noise entirely”
Forest Management Wildfire
- “wildfire rationale... does not survive contact”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires”
Recreation Tourism Public Use
- “where we go to photograph fungi, insects, native plants, and birds”
- “outfitters, guides, and tour operators who actually hold permits”
- “people who plan their recreation, their photography, their time watching corvids and woodpeckers”
- “lost recreation benefit at a minimum of $6.1 million a year”
Economic Impact Fiscal
- “net present value ranging from -$92 million to +$199 million”
- “recreation losses of at least $6.1 million a year”
- “carrying a $6.9 billion maintenance backlog on its existing road system”
- “total timber volume affected by this rule is less than 0.5 percent”

What it names

National Forests: Umpqua National Forest

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 The Umpqua National Forest is where we go to photograph fungi, insects, native plants, and birds, and where I have been honored to see corvids and woodpeckers moving through a landscape that has not yet been carved apart. What the agency is now proposing would put exactly that kind of place at risk, and the agency's own record makes a stronger case against the rescission than for it. The wildfire rationale the agency offers for rescinding the 2001 Roadless Area Conservation Rule does not survive contact with the agency's own draft environmental impact statement. The DEIS states plainly: "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." That finding appears in the same document that is supposed to support this proposal. The birds I watch along the Umpqua depend on intact forest structure, and the DEIS's own cited research confirms that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. The agency must explain, with specificity, why the proposal departs from its own ignition data and its own findings on what roads do to the ecological communities those roads would penetrate. The economic case fares no better. The DEIS 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." Against those figures, the agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service, offset by recreation losses of at least $6.1 million a year, with a net present value ranging from -$92 million to +$199 million. That range does not establish a net benefit. The Forest Service is also carrying a $6.9 billion maintenance backlog on its existing road system. Oregon alone holds 211 inventoried roadless areas totaling 1,937,741 acres, and across the Pacific Northwest region 1,522 municipal water intakes sit in watersheds containing affected roadless areas. The agency must reconcile its proposal with a cost-benefit analysis that cannot demonstrate the action pays, and must explain how expanding a road system already billions of dollars behind on maintenance serves the public interest. The regulatory flexibility analysis reaches its no-significant-impact conclusion by spreading estimated losses across every small firm in the relevant sector nationally, rather than assessing the outfitters, guides, and tour operators who actually hold permits in the affected areas and who the DEIS itself identifies as affected parties. 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 agency should withdraw the certification and conduct an analysis of the specific small businesses operating in the roadless areas at issue, not the national average firm. Finally, 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. The people who plan their recreation, their photography, their time watching corvids and woodpeckers in places like the Umpqua around the expectation that roadless areas will remain roadless have built that expectation on a rule that has been in place for decades. This comment is one such reliance interest. The agency must identify and weigh the interests described in the comments it receives, including this one, before it proceeds. I believe we should be good stewards. The land is not simply a resource to extract from. The agency's own record supports keeping these areas intact, and the agency has not explained why it is choosing otherwise. I oppose the rescission. Sincerely, Candy Mitchell Myrtle Creek, Oregon