Comment Analysis · Docket FS-2025-0001

FS-2025-0001-337756

Opposes rescissionA2 moderateSubstance 13/24Owed an answerPosted September 8, 2026 On Regulations.gov

In short: The comment establishes that the agency's analysis is deficient because it relies on qualitative water quality assessments despite Table 35 identifying over 7,000 municipal water intakes, and fails to model the cumulative effects of the statutory timber volume mandate (Table 4) combined with the proposed rule's harvest projections on Deschutes National Forest resources.

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
- “drinking water question alone should stop this rulemaking”
- “more than 7,000 municipal water intakes within watersheds”
- “no quantitative modeling of sediment loads, pathogen risk”
- “watershed-specific, quantitative modeling of drinking water quality effects”
Recreation Tourism Public Use
- “places where I hike, bike, paddle, climb, photograph wildlife and birds, and ski”
- “forests I use for hiking, wildlife watching, and photography”
- “Deschutes National Forest lands”
Governance Policy Process
- “cumulative effects analysis is also inadequate”
- “agency must integrate the statutory volume mandate with IRA-specific harvest projections”
- “respond to that combined analysis before this rule moves forward”
Resource Development Extraction
- “fulfill the wishes of the corporate donors and logging and extraction industries”
- “profit driven”
- “sell a quantity of timber... at least 250 million board feet greater”

What it names

National Forests: Deschutes National Forest

The comment

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

The trails along the Metolius River, around Three Creeks Lake, the Tam McArthur Rim, Paulina Lake, and East Paulina Lake are some of the places where I hike, bike, paddle, climb, photograph wildlife and birds, and ski. These are Deschutes National Forest lands, and I am filing this comment to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. The drinking water question alone should stop this rulemaking until proper analysis is done. The agency's own document notes, in Table 35, that "there are more than 7,000 municipal water intakes within watersheds containing potentially affected inventoried roadless areas." That figure represents a public health exposure of extraordinary scale, yet the water quality analysis in the document is entirely qualitative. There is no quantitative modeling of sediment loads, pathogen risk, or treatment cost increases that would follow from road construction and timber harvest in these watersheds. Clean water matters to me directly, and an assertion that Best Management Practices reduce but do not eliminate impacts is not an analysis. The agency must provide watershed-specific, quantitative modeling of drinking water quality effects before this rule is finalized. The cumulative effects analysis is also inadequate. The document lists as a reasonably foreseeable action, in Table 4, a statutory mandate that "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." The document projects that its own alternatives could increase sawtimber harvest by 4 to 10 percent nationally, but nowhere does it model both obligations operating at the same time on inventoried roadless area resources. The forests I use for hiking, wildlife watching, and photography in the Deschutes could face pressure from both mandates simultaneously, and the agency has not told the public what that means. The agency must integrate the statutory volume mandate with IRA-specific harvest projections across all resource topics and respond to that combined analysis before this rule moves forward. This change is simply to fulfill the wishes of the corporate donors and logging and extraction industries and is not about the future, the planet, or the health of our children. It is short sighted and profit driven and is being sold as fire safety under the guise of protecting communities from wildfire and resource management while actually accomplishing the opposite.