Comment Analysis · Docket FS-2025-0001

FS-2025-0001-343338

Opposes rescissionA0 noneSubstance 8/24Posted September 12, 2026 On Regulations.gov

In short: The comment documents the specific local impacts of the proposed Roadless Rule rescission in Central Oregon, citing 200,000 acres of Inventoried Roadless Areas in the Deschutes, Ochoco, and Crooked River units, and challenges the DEIS's claim that the action restores local decision-making power.

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

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

  • Water Quality Quantity
    • “ensured clean drinking water for 25 years”
    • “degrade my community's drinking watershed”
    • “threaten water quality for fish”
    • “protecting the clean water”
  • Wildlife Habitat
    • “protected wildlife habitat”
    • “disrupt wildlife habitat”
    • “spread invasive species”
    • “biodiversity that roadless forests provide”
  • Governance Policy Process
    • “zero public meetings, shortened comment periods”
    • “disregard for the public input received during scoping”
    • “undemocratic and irresponsible”
    • “most extensive public engagement process in the history of federal rule making”
  • Climate Carbon Storage
    • “make our forests less resilient in this time of climate change”
    • “increasing wildfire regimes”
    • “climate resilience”

What it names

National Forests
Deschutes National ForestOchoco National Forest

The comment

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

Secretary Rollins: I strongly oppose the proposal to eliminate, alter, or weaken the Roadless Rule. This terrible proposal 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. I live in Central Oregon, where we have almost 200,000 acres of Inventoried Roadless Areas in the Deschutes National Forest, Ochoco National Forest, and Crooked River National Grassland. These roadless areas have protected wildlife habitat, boosted local economies, and ensured clean drinking water for 25 years. 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. Roads in these areas would dramatically increase wildfire, degrade my community’s drinking watershed, and threaten water quality for fish. Roads in these areas will make our forests less resilient in this time of climate change and increasing wildfire regimes. Additionally roads will spread invasive species and disrupt wildlife habitat. In areas like Central Oregon, where I live, the timber industry has been in decline for decades, and opening roadless areas to logging will not yield a meaningful economic return. Rather, 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. 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. The original Roadless Rule resulted from the most extensive public engagement process in the history of federal rule making, 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 irresponsible. The USDA should strengthen its commitment to protecting the clean water, climate resilience, recreation, and biodiversity that roadless forests provide. ONCE ROADS AND CLEARCUTS FRAGMENT OR LANDSCAPES, THE DAMAGE IS PERMANENT. PLEASE take the No Action alternative and maintain full Roadless Rule protections for America's lands. Michele McKay Bend, Oregon

Keep learning. Keep speaking up.The Roadless Rule depends on public engagement. Share what you've learned.

© 2026 roadless.org - Defending America's Last Wild Forests

Privacy Policy|Questions or concerns? noroads@roadless.org|Follow us: @defendroadless