Comment Analysis · Docket FS-2025-0001

FS-2025-0001-333500

Opposes rescissionA1 strongSubstance 16/24Owed an answerPosted September 7, 2026 On Regulations.gov

In short: The comment places on the record specific peer-reviewed data regarding wildfire ignition density and water supply dependencies, cites specific pages of the Economic Analysis that concede unquantified recreation losses, and requests that the FEIS quantify recreation exposure in affected IRAs before relying on an analysis that admits it cannot measure the magnitude of those losses.

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

A1 strong: Must be answered — it names the law.

Owed an answer on Analytical gap, Evidence, Legal.

Standard dismissals it defeats

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.
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.
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.

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.
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.

Topics

Recreation Tourism Public Use
- “countless hikes in this area”
- “lose access to recreate in these incredible places”
- “moment of solitude to soak in the peace”
- “forgone recreation benefits”
Water Quality Quantity
- “integrity of the headwaters themselves could be compromised”
- “national forests supply drinking water to at least 124 million people”
- “Roads are a major cause of water pollution”
- “maintaining clean drinking water for communities”
Forest Management Wildfire
- “peer-reviewed science shows the opposite”
- “wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads”
- “building roads into roadless areas is likely to result in more fires”
- “we don't need to rescind a policy that could make this even worse”
Legal Regulatory Framework
- “Certain-direction losses of unknown and unmeasured magnitude are precisely what NEPA requires”
- “I request the FEIS quantify recreation exposure”
- “Robertson, 490 U.S. 332; State Farm, 463 U.S. 29”
- “removal of that protection will lead to their fragmentation”

What it names

National Forests: Mt. Hood National Forest
Roadless areas: Larch
Law cited: 463 U.S. 29 490 U.S. 332

The comment

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

Dear Secretary Rollins and Chief Schultz: As a lifelong Oregonian, it is clear to me the value of the 2001 Roadless Area Conservation Rule and the protection it provides to forest lands that help make this state such a great place to live. These areas are still intact because of sustained regulatory protection, and removal of that protection will lead to their fragmentation. The Larch Roadless Area in Mt. Hood National Forest holds particular significance for me. I've gone on countless hikes in this area, to Wahclella Falls, Oneonta Gorge, and Wiesendanger Falls to name a few. The area makes up part of the Columbia Gorge's Waterfall Corridor, one of the crown jewels of the state. These hikes let me connect with our forests, enjoy time with my family, and admire truly breathtaking landscapes crafted by nature. To get to Wiesendanger Falls requires a 1.4 mile hike, past all of the crowds at Multnomah Falls, where you can have a moment of solitude to soak in the peace and awesome power of the falls. Like many places in roadless areas, the hike to get there is what makes it worth going to in the first place. If this rule is rescinded, I could lose access to recreate in these incredible places - the Multnomah Falls, Wahclella Falls, and Elowah Falls, and others I haven't had a chance to see yet, like Wahkeena Falls and Angels Rest. Not only that, but the integrity of the headwaters themselves could be compromised. Regarding the Larch in the Mt. Hood National Forest, Oregon: Although proponents of rolling back the Roadless Rule claim it is needed for wildfire management, the peer-reviewed science shows the opposite. A 2026 study in Fire Ecology by Aplet, Hartger & Dietz analyzed 32 years of wildfire data across all eight contiguous-U.S. Forest Service regions and found wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads, compared to just 1.97 fires per 1,000 hectares in inventoried roadless areas—a fourfold difference. A separate national analysis (Balch et al., PNAS 2017) found that 84% of all U.S. wildfires are human-caused. Roads are the primary vector for human ignitions, so building roads into roadless areas is likely to result in more fires, not fewer. Oregonians painfully watch as thousands of acres of wildfires burn in our state every year - we don't need to rescind a policy that could make this even worse. The U.S. National Forests are the headwaters of our great rivers and the largest source of municipal water supply in the nation. According to DellaSala (2011), national forests supply drinking water to at least 124 million people in more than 3,400 communities across 33 states—roughly a third of all national-forest runoff originates in inventoried roadless areas. Roads are a major cause of water pollution: erosion rates from logging roads have been documented as much as 850% higher than from undisturbed forest. Because the 2001 Roadless Rule protects these headwaters, it is vital for maintaining clean drinking water for communities across the country. Major U.S. cities including Portland, where I live, receive a significant portion of their water supply from national forests. The Analysis Concedes Recreation Losses Are "Most Likely," Quantifies Them as Costs, and Cannot Even Count the Visitors at Risk The Economic Analysis concedes at page 25: "In the long-term, any changes in aggregate economic benefit to recreationists that occur under the proposed rule are most likely to be losses because timber harvest and road construction is anticipated to negatively change the recreation settings and opportunities for trail-based and dispersed area recreation within potentially affected IRAs… The magnitude of those losses is unknown." At page 30 it books real costs: "Costs include forgone recreation benefits (minimum of $6.1 million annually) and forgone passive use values ($5.3 to $11.5 million annually) from increases in timber harvest in roadless areas." At page 28 it concedes the mechanism: "The construction and use of roads can degrade the unique characteristics of roadless areas… leading to loss of conservation values… These impacts from road development could negatively impact tourism and outdoor recreation." And at page 16 it admits it cannot even measure the exposure: "The number of recreation visits to IRAs is unknown and, thus, the recreation visitor spending in local communities associated with IRA recreation cannot be directly quantified." Certain-direction losses of unknown and unmeasured magnitude are precisely what NEPA requires an agency to analyze rather than wave through. Robertson, 490 U.S. 332; State Farm, 463 U.S. 29. I request the FEIS quantify recreation exposure (visitation and spending) in affected IRAs before relying on an analysis that concedes losses it cannot measure. These lands don't need roads, they need protection. The Rule gives them that. In earnest, Amber Gomez CommentID: RLC-20260907-X914GF