Supports rescissionA0 noneSubstance 5/24Posted August 28, 2026 On Regulations.gov
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
A0 none: Counted, not answered.
Still open to the agency
Alternative already eliminatedThe agency says it considered and eliminated the alternative the comment proposes, with a reason. Cannot be defeated from the comment text alone.
Already addressedThe 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 decisionThe agency says the point belongs to a later, site-specific decision. Cannot be defeated from the comment text alone.
Misreads the proposalThe agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
Not requiredThe agency says the analysis the comment asks for is not required. Cannot be defeated from the comment text alone.
Preference notedThe 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 shownThe agency says the comment asserts a harm without showing how the action causes it. Defeated when the comment shows the mechanism.
Outside the scopeThe agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.
Certified not substantiveThe agency certifies the comment raises nothing substantive. Defeated when the comment alleges illegality, which is substantive by the definition the certification runs on.
Cougar BluffLimpy RockPonderosa PineSugar PineWhite PineWilliams Creek
The comment
Dear Secretary Rollins,
I support the removal of the 2001 Roadless Area Conservation Rule. In general, I think that forest management decisions should be made at the local (District and Forest) levels because it is the local people that know their landscape best.
I will therefore speak to the local area I know best – the North Umpqua Ranger District on the Umpqua National Forest in Oregon. The roadless areas that I am familiar with are Williams Creek, Cougar Bluff, Limpy Rock, Calf-Copeland and Medicine Creek. All of these areas are characterized by steep slopes of varying aspects. There are numerous exposed columnar basalt formations and until the early 2000’s they were primarily large old growth and second growth Douglas-fir stands intermixed with other species such as Western hemlock, mountain hemlock, true firs, Western white pine, sugar pine and some ponderosa pine. There were also open meadows, high lakes and areas of oak scrub.
The prevailing reason that these areas are unroaded, is because of the steep rocky slopes. It is impractical and costly to build roads into these areas and there was no reason to do so. That has not changed. A roadless area designation does not change the conditions of the ground and has not protected them.
What has happened to these areas is that they are catastrophically burnt. I do not use the term catastrophic, lightly or to overstate the situation. Employees on the North Umpqua Ranger District used to affectionately call it the asbestos forest because it didn’t burn. If there were lightening busts, and there were, the fires remained small and manageable. 1987 was a particularly bad year for lightening and it seem like the entire forest was on fire, but that was nothing compared to fires in the 2000’s. 1987 was characterized by many small fires. Some got large because there wasn’t man-power available to staff them. But “large” then is not was “large” is now.
Currently, each of these roadless areas has a watershed-sized, catastrophic burn scar in it. And all of those fires have happened in the 2000’s. Whole forests have been wiped out, soil has been sterilized, water quality has been reduced, protective root structures are gone and highly flammable brush has taken over these landscapes and the brush is currently 10’ or more tall. This is a recipe for yet another wildfire disaster. Many of these sites have burned multiple times in the last 25 years. That is dramatically different from the “asbestos forest” that it should be.
Additionally, there are other resources that have been impacted. Recreation facilities like historic shelters and outhouses have burned and have not been rebuilt. Once highly trafficked trails are lost in the jumble of downed trees, some historic trails are likely lost to the public at this point. There are only a few old-timers that could possibly find them and certainly not in their entirety. Landslides resulting from lost root structure have wiped out many sections of trail. Roads accessing other parts of the forest have not been maintained because of the landscape sized fires and sheer numbers of downed trees.
If the 2001 Roadless Area Conservation Rule is reversed, I’m hopeful that local land managers will have more tools at their disposal to manage these lands to prevent catastrophic fires, manage the fires when they come and manage the disaster that comes in the aftermath.