Comment Analysis · Docket FS-2025-0001

FS-2025-0001-275493

Opposes rescissionA3 weakSubstance 13/24Owed an answerPosted August 27, 2026 On Regulations.gov

In short: The comment establishes that the agency's regulatory flexibility analysis fails to assess site-specific economic impacts on small entities in the named roadless areas, and requests the agency analyze an alternative retaining the 2001 rule's protections for Mcclellan Mountain, Salmon-Huckleberry, and Gifford Pinchot areas.

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

A3 weak: Substantive, but easier to set aside.

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.
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.
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.
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

Water Quality Quantity
- “protecting safe, bountiful drinking water”
- “higher sedimentation loading into streams”
- “breach of that trust”
- “no way that rescinding the roadless rule makes good public health sense”
Recreation Tourism Public Use
- “hiking, camping, picking huckleberries”
- “leave the road noise behind”
- “lost recreation benefit at a minimum of $6.1 million a year”
- “small outfitters and guides who work this same country”
Environmental Protection Biodiversity
- “protect the forest parcels and their habitat interconnectivity”
- “critical ecosystem functions”
- “looking for mountain goats and woodpeckers”
- “irreversible damage”
Legal Regulatory Framework
- “small-business certification contradicts the analysis”
- “withdraw the certification and assess the impact”
- “analyze in the DEIS an alternative that retains the 2001 rule's protections”
- “provide a reasoned explanation for it on the record”

What it names

National Forests: Gifford Pinchot National Forest Malheur National Forest Malheur National Forest Mt. Hood National Forest
Roadless areas: Mcclellan MountainSalmon - Huckleberry

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 am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule, and specifically about these inventoried roadless areas: - Mcclellan Mountain (21,213 acres), Malheur NF, Oregon - Salmon - Huckleberry (17,570 acres), Mt. Hood NF, Oregon - Gifford Pinchot (213,000 acres), Washington 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 grew up in Oregon, a state with a rich and complicated forestry history. I learned how to walk on a backpacking trip with my parents in the Malheur National Forest. 30 years later I still hike and camp in the forests of Oregon and Washington every year, and I cannot imagine the futures of our states without these forests remaining intact in their current versions. Recently, in the Gifford Pinchot NF I was looking for mountain goats and woodpeckers on an ascent up to a peak. Pikas as well are always my favorite of the alpine wildlife. Living in Portland, we are lucky to have great quality drinking water from the Bull Run Watershed, which is part of the Mt Hood National Forest. Protecting the integrity of this National Forest is absolutely critical to protecting safe, bountiful drinking water for our metropolitan area. It is absolutely NOT ok to jeopardize such critical infrastructure and basic human needs such as drinking water by introducing more roads, fragmentation, forest fire potential in an already extremely vulnerable wildfire area, and higher sedimentation loading into streams. I work in drinking water quality and there is just no way that rescinding the roadless rule makes good public health sense. We all need clean drinking water. We rely on our government to help protect the natural assets that make it available. This would be a breach of that trust. The Salmon-Huckleberry wilderness is my favorite part of Mt Hood National Forest. It's just an hour away from where I live so I visit it throughout the seasons, hiking, camping, picking huckleberries. It's already a heavy-traffic and somewhat fragmented National Forest due to the PCT and its proximity to outdoors-loving Portland. We need to protect the forest parcels and their habitat interconnectivity that remains, so that critical ecosystem functions and the incredible natural beauty that is a cornerstone of our state's identity, economy, and history is protected. Hiking trails that take you into the forest and leave the road noise behind are the top reason a lot of my friends have moved here from California. We can't lose this, especially for an act that would have such low value in terms of taxpayer dollars and revenue. The forests as they are provide far more benefit than the proposed rule, which would cause irreversible damage. 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 I hike and camp in these areas, and the small outfitters and guides who work this same country help people like me get out there. They deserve a real assessment. 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. 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, Clare McClellan Portland, OR