Comment Analysis · Docket FS-2025-0001

FS-2025-0001-358522

Opposes rescissionA1 strongSubstance 15/24Owed an answerPosted September 12, 2026 On Regulations.gov

In short: The comment places on the record specific data from the agency's DEIS regarding bird abundance, wildfire ignition rates, economic net present value, and sediment production, arguing that the proposed rescission contradicts the agency's own findings and legal precedents, and requests a specific on-the-record explanation for these discrepancies.

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, 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
- “spent in roadless areas”
- “float rivers all over Oregon”
- “listen and learn bird calls”
- “photograph plants and mushrooms”
Environmental Protection Biodiversity
- “bird richness declines with road presence”
- “road-noise experiments... cut bird abundance”
- “degrade habitat”
- “haven for old trees”
Water Quality Quantity
- “clean water is essential to all life”
- “municipal water intakes sit in watersheds”
- “vulnerable to road-related sediment”
- “roads... produce up to 90 percent of the sediment”
Forest Management Wildfire
- “human-caused wildland fire is nearly five times more likely”
- “Roadless areas are less likely to burn”
- “reconcile the rescission with the ignition data”
- “high risk from uncharacteristic wildfire effects”

What it names

National Forests: Siuslaw National Forest Willamette National Forest
Roadless areas: Bull Of The WoodsDrift CreekHebo 1a
Law cited: 28 U.S.C. Section 1291

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 For the past 55 years, most all of my free time has been spent in roadless areas. I float rivers all over Oregon, including the Willamette, the Rogue and the McKenzie. I listen and learn bird calls. I photograph plants and mushrooms. Drift Creek, in the Siuslaw National Forest, is a place I have gone for 25 years. I even broke my leg in there. It is a haven for old trees and clean water, and a road would devastate those ancient forests and steep slopes. I am filing this comment to oppose the rescission of the 2001 Roadless Area Conservation Rule. Oregon holds 211 inventoried roadless areas totaling 1,937,741 acres. Drift Creek at 6,333 acres, Hebo 1a at 13,930 acres, and Bull of the Woods at 53 acres in the Willamette National Forest are among them. These are not abstract figures. They represent the country where I have spent the better part of my life. The agency's own environmental impact statement contains research on birds that gives me serious concern. The DEIS cites findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. I have spent decades learning bird calls in places like these. The agency should explain on the record what weight it gave this evidence, and why road-building is consistent with it. On wildfire, the proposal's reasoning contradicts the agency's own record. The agency's DEIS states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." Roadless areas are less likely to burn. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence, and that it reconcile the rescission with the ignition data in its own DEIS, which reports far higher fire density on roaded land than inside the affected roadless areas. Roads cost money, add pollution, and degrade habitat. I do not want my tax dollars paying for the destruction of habitat. The agency should reconcile the proposal with its own economic analysis, which projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. The agency's own record also acknowledges: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency needs to explain on the record how an action whose own cost-benefit analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog. Across the Pacific Northwest region, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. Clean water is essential to all life. Drift Creek is itself a clean water system, and the steep slopes there make it acutely vulnerable to road-related sediment. The agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale. The agency should explain what protections, if any, it intends for these watersheds once the national rule is gone. The proposal argues for state-by-state approaches over a single national rule. The agency previously described its dissatisfaction with the Roadless Rule's nationwide approach, and the courts took up that question directly. The Tenth Circuit held: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The agency should address the Tenth Circuit's holding that the 2001 rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness, and explain the basis for any contrary position. It should also address how this proposal avoids the deficiencies identified when the agency last replaced the national rule with a state-by-state approach. I have sent several letters in and have heard nothing back from agencies on what the public process is. That silence does not inspire confidence that this rescission is being weighed against the record. The agency should respond to each of these points. Sincerely, Carol Savonen Philomath, Oregon