Comment Analysis · Docket FS-2025-0001

FS-2025-0001-316982

Opposes rescissionA2 moderateSubstance 14/24Owed an answerPosted September 7, 2026 On Regulations.gov

In short: The comment establishes that the DEIS lacks quantitative water quality modeling and a cumulative analysis integrating the statutory timber harvest mandate of the One Big Beautiful Bill Act with roadless area impacts, while documenting specific local exposure to fire and water risks in the Ochoco and Deschutes 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

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

Water Quality Quantity
- “primary water sources for all of Central Oregon”
- “Old growth forests and undamaged riparian areas are the primary sources of clean water”
- “no quantitative modeling of sediment loads, pathogen risk, or treatment cost increases”
- “protect the drinking water that flows from these watersheds to millions of people”
Forest Management Wildfire
- “The more access roads open into forest lands, the more human-caused fires will follow”
- “Rescinding roadless protections is not a fire management strategy”
- “invitation to the very ignition sources already burning the land”
- “address directly how expanded road access interacts with human-caused fire risk”
Resource Development Extraction
- “Roads are a prelude to logging the forests, which I adamantly oppose”
- “Cumulative timber pressure is the third reason”
- “Directs the Forest Service to annually... sell a quantity of timber... at least 250 million board feet greater”
- “I oppose logging in the federal forests anywhere except the Wildland Urban Interface”
Recreation Tourism Public Use
- “I camp at the Ochoco Forest Campground and hike Lookout Mountain”
- “I photograph birds, horses, trees, and views”
- “The national forests must be reserved for recreation, wildlife, and environmental management”
- “Roadless areas must be maximized, not removed”

What it names

Roadless areas: Lookout Mountain

The comment

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

The Ochoco draws me in every season. I camp at the Ochoco Forest Campground and hike Lookout Mountain. Out there I photograph birds, horses, trees, and views. I watch old growth Ponderosas, birds and squirrels, wild horses, and magnificent vistas. I oppose rescinding the 2001 Roadless Area Conservation Rule, and I want my reasons on the record. Water is the first reason. The Crooked River and the Deschutes River, along with groundwater, are the primary water sources for all of Central Oregon. Old growth forests and undamaged riparian areas are the primary sources of clean water and must be left untouched for centuries. Roads are a prelude to logging the forests, which I adamantly oppose. The scale of what is at stake is stated plainly in Table 35 of the DEIS: "there are more than 7,000 municipal water intakes within watersheds containing potentially affected inventoried roadless areas." Despite documenting that exposure, the water quality analysis is entirely qualitative. There is no quantitative modeling of sediment loads, pathogen risk, or treatment cost increases that road construction and timber harvest would produce. Saying that Best Management Practices reduce but do not eliminate impacts is not an analysis. The agency must explain, before finalizing this rule, how it intends to protect the drinking water that flows from these watersheds to millions of people, and it must do so with specifics, not programmatic language. Fire is the second reason. I live across the Deschutes River from forest that has had four fires in the last two years, three of them human caused. The more access roads open into forest lands, the more human-caused fires will follow. Hikers and bikers rarely cause fires, but humans in vehicles do. Rescinding roadless protections is not a fire management strategy. It is an invitation to the very ignition sources already burning the land I can see from where I live. The agency should address directly how expanded road access interacts with human-caused fire risk, and put a real answer to that question in this record. Cumulative timber pressure is the third reason. The DEIS frames the possibility that certain alternatives could increase sawtimber harvest by some margin as a benefit, while Table 4 of the same document acknowledges an ongoing reasonably foreseeable action: the One Big Beautiful Bill Act, which "Directs the Forest Service to annually, beginning in FY2026 and through FY2034, sell a quantity of timber on National Forest System land that is at least 250 million board feet greater than the quantity that was sold in the previous fiscal year." That statutory mandate runs independently of this rulemaking, yet nowhere in the document does a cumulative analysis combine both pressures and measure their joint effect on inventoried roadless area resources. The agency cannot treat a decade-long escalating harvest obligation as background noise. It must integrate that mandate with IRA-specific projections before this rule is finalized. The national forests must be reserved for recreation, wildlife, and environmental management. Roadless areas must be maximized, not removed. I oppose logging in the federal forests anywhere except the Wildland Urban Interface, and I urge the agency to withdraw this proposal.