Comment Analysis · Docket FS-2025-0001

FS-2025-0001-343202

Opposes rescissionA0 noneSubstance 7/24Posted September 12, 2026 On Regulations.gov

Small family — One letter sent by 3 to 9 people, copied or lightly reworded. One of 4 submissions in its group. See the letter, its submissions and topics.

In short: The comment documents specific local impacts in Central Oregon, including threats to the Bend Municipal Watershed and wildlife corridors in the Metolius Basin, while asserting that the agency's DEIS mischaracterizes the rule's effect on local decision-making and that the public comment process was inadequate.

Scored with own additions — A family member whose own text beyond the shared letter was scored and combined with the letter's score.

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 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.
Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
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.
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.

Topics

Environmental Protection Biodiversity
- “protected wildlife habitat”
- “maintaining mule deer and elk migration corridors”
- “damage recreation areas, scenic views, and wildlife habitat”
- “Roadless forests represent some of the most intact, resilient ecosystems”
Water Quality Quantity
- “ensured clean drinking water for 25 years”
- “More roads will also degrade drinking watersheds”
- “threaten water quality for fish species and the drinking water supply”
- “protecting the clean water”
Governance Policy Process
- “abridged and inadequate public comment process”
- “zero public meetings, shortened comment periods”
- “disregard for the public input received during scoping”
- “undemocratic and deeply irresponsible”
Climate Carbon Storage
- “reduce the carbon storage we need to combat climate change”
- “climate resilience”
- “erode forest resilience in the face of rapidly shifting wildfire regimes”

What it names

National Forests: Deschutes National Forest Ochoco National Forest
Roadless areas: Lookout Mountain

The comment

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

Secretary Rollins: In Central Oregon, we have almost 200,000 acres of Inventoried Roadless Areas in the Deschutes National Forest, Ochoco National Forest, and Crooked River National Grassland have protected wildlife habitat, boosted local economies, and ensured clean drinking water for 25 years. From protecting recreational opportunities in Newberry Caldera, to safeguarding sweeping views atop Lookout Mountain in the Ochocos, to maintaining mule deer and elk migration corridors in the Metolius Basin, the Roadless Rule is vital to our local communities. I STRONGLY OPPOSE THE USDA’S PROPOSAL to eliminate, alter, or weaken the Roadless Rule, which would reduce protections across 44.7 million acres of public lands managed by the US Forest Service nationwide. The agency should select Alternative 1, the No Action alternative, and leave current roadless protections in place. Rescinding the Roadless Rule is not practical. The USFS already has billions of dollars in deferred maintenance on its existing 370,000+ miles of roads, and this rule rescission will only compound the problem by adding expensive, infrequently used backcountry roads on the taxpayers’ dime. Worse still, in areas like Central Oregon, where the timber industry has been in decline for decades, opening roadless areas to logging will not yield a meaningful economic return. Instead, increasing roads will damage recreation areas, scenic views, and wildlife habitat, and eliminate the core reasons people choose to live, work, and play in Central Oregon. Rescinding the Roadless Rule is also dangerous. More roads also mean more fires: research shows wildfires are four times more likely to ignite near roads. Fighting those fires in remote areas is dangerous, costly, and diverts resources from protecting communities. More roads will also degrade drinking watersheds. National Forests and Grasslands are the single most important source of municipal water supply in the United States, and Roadless Areas filter drinking water for over 2 million Oregonians. In Central Oregon, the Bend Municipal Watershed begins in the headwaters of Bridge Creek and Tumalo Creek in the Deschutes National Forest. Losing Roadless protections will threaten water quality for fish species and the drinking water supply for more than 100,000 people in Bend, and tens of millions of people across the country. And, rescinding the Roadless Rule makes our forests less resilient. Roads spread invasive species, disrupt wildlife corridors, and erode forest resilience in the face of rapidly shifting wildfire regimes. Logging these roadless forests would also directly eliminate overstory and understory habitats, harm First Foods, and reduce the carbon storage we need to combat climate change. This rescission would not, as the DEIS claims, restore the decision-making power of our local forest managers. Instead, as the DEIS expressly admits, it would further the misguided goal of ramping up timber production on public lands while disempowering the Forest Service staff and Central Oregonians who care for these roadless areas. Sacrificing our local values for short-term logging profits is not sound policy; it is a net loss for communities, economies, and future generations. Roadless forests represent some of the most intact, resilient ecosystems left in our country, but once roads and clearcuts fragment our landscapes, the damage is permanent. Despite the clear consequences of rescission and the vocal majority opposing the Proposed Rule, the USDA continues this rollback through an abridged and inadequate public comment process. The original Roadless Rule resulted from the most extensive public engagement process in the history of federal rulemaking, with over 95% of commenters supporting strong protections. Now, the agency is attempting to dismantle these protections with zero public meetings, shortened comment periods, and a disregard for the public input received during scoping. This is undemocratic and deeply irresponsible for decisions of such sweeping consequence. For more than two decades, the Roadless Rule has been a cornerstone of sound forest management, balancing ecological, economic, and cultural values. Weakening or repealing it would be a grave mistake. Both Alternatives 2 and 3 will have severe consequences for wildlife, biodiversity, clean water sources, climate resilience, cultural resources, local economies, outdoor recreation, and the health of our nation's wildest forests. The USDA should abandon this damaging effort and instead strengthen its commitment to protecting the clean water, climate resilience, recreation, and biodiversity that roadless forests provide. I urge the agency to take the No Action alternative and maintain full Roadless Rule protections for America's wild forests. Sincerely, Donnie N Stelma