Comment Analysis · Docket FS-2025-0001

FS-2025-0001-296778

Opposes rescissionA3 weakSubstance 9/24Owed an answerPosted September 1, 2026 On Regulations.gov

In short: The comment documents that the rescission of the Roadless Rule would open the Mt. Hood Additions in the Mt. Hood National Forest to road construction, citing specific scientific data on fire ignition proximity and ecosystem degradation to argue that the current rule is essential for fire management and forest health.

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 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

Forest Management Wildfire
- “the rule has been good for fire management”
- “bulk of wildfires start within 50 m of a road”
- “increased fire risk due to reduced moisture retention”
- “Roadless Rule is essential for healthy forests, fire and communities”
Environmental Protection Biodiversity
- “roads fragment ecosystems and thus harm forest health”
- “supporting clean air and water, biodiversity”
- “essential for sustaining ecosystem services”
- “harm... animal populations”
Water Quality Quantity
- “dwindling salmon population”
- “harm... water and air quality”
- “supporting clean air and water”
Economic Impact Fiscal
- “massive economic impact”
- “no valid argument the rescinding the roadless rule makes economic sense”
- “economic issue”

What it names

National Forests: Mt. Hood National Forest Mt. Hood National Forest San Juan National Forest
Roadless areas: Mt. Hood Additions

The comment

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

Dear Chief Tom Schultz: As a former wildland firefighter and current municipal firefighter, my objection to the rescission is operational, not ideological — the rule has been good for fire management, and the notice doesn't show otherwise. I have been recreating and working in National Forests since before I could walk. Professionally, I spent 3 seasons as a commercial backpacking guide in the San Juan National Forest in southern Colorado, and frequently was adjusting trips to avoid wildfires and smoke. Afterward, I switched to chasing wildfire with the Forest Service as a wildland firefighter in the Columbia River Gorge Nation Scenic Area in region 6. I've used roads, trails and rivers to access wildfires, both human and lightning caused. I've personally held responsibility for starting a new spot fire on the side of a road with the hot tailpipe of my type 6 engine while actively fighting a wildfire. The lucky ending of that story is that an engine staffed with firefighters is equipped to put that fire out quickly. The same cannot be said of most other vehicles. I'm now quite conscious of not parking or idling in dry grass. J.K. Balch, B.A. Bradley, J.T. Abatzoglou, et al. in a review of human caused vs lighting caused fires from 1912 to 2012 found that "the human-caused fire season was three times longer than the lightning-caused fire season and added an average of 40,000 wildfires per year across the United States." This is not just a huge ecological impact, it a massive economic impact. There is no valid argument the rescinding the roadless rule makes economic sense for Americans. A roadless area that I have fought fire in and frequently recreate in is the Mt. Hood Additions in the Mt. Hood National Forest, Oregon. Rescinding the Roadless Rule would open the Mt. Hood Additions, Mt. Hood National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. Olden JD, Postel SL, Dombeck MP, et al. (2026) call roadless areas "essential for sustaining ecosystem services, supporting human well-being, and advancing broader conservation and resilience goals under increasing climatic and land-use pressures". This is especially clear in the Mt. Hood NF, where the dwindling salmon population is a frequent topic of concern for recreation, conservation and economic reasons. To those of us familiar with forests, wildfire, firefighting and the science around all three, it is undebatable that the Roadless Rule is essential for healthy forests, fire and communities. I don't need Aplet, G.H., Hartger, P. & Dietz, M.S. to tell me that the bulk of wildfires start within 50 m of a road. I've seen it, fought them, and unfortunately been a part of that statistic. I don't need Victoria J., Bennett to explain to me how roads fragment ecosystems and thus harm forest health, water and air quality, and animal populations, I've seen and experienced it. And when Zhou, D., Xiao, J., Liu, S. et al. note that “Within 1 km of roads, forests show 18.6% lower forest cover, 2.7 m shorter canopy height" I know that directly translates to increased fire risk due to reduced moisture retention and increased sun exposure in the understory. I've seen this as I've "slung the weather" with a sling psychrometer to measure temperature and relative humidity as a lookout on a fire. What is obvious even to the casual observer, and quantified in numerous studies, is that roadless areas benefit us in countless ways including by supporting clean air and water, biodiversity, and more natural fire patterns. This is not just a conservation or fire issue, it is a community health issue, a cultural issue, and economic issue. The Department should reject this proposal and maintain the protections the Roadless Rule has provided since 2001. Yours sincerely, Greta Smith CommentID: RLC-20260901-KXNZRC