Comment Analysis · Docket FS-2025-0001

FS-2025-0001-390633

Opposes rescissionA0 noneSubstance 7/24Posted September 14, 2026 On Regulations.gov

Exact copy — Byte-identical to another submission. This comment stands for 2 submissions in its group.

In short: The comment establishes that the rescission of the Roadless Rule specifically threatens the Jumpoff Joe area in the Umatilla National Forest by enabling road construction that fragments habitat and facilitates industrial extraction, while documenting significant public opposition and economic burdens associated with the proposed policy change.

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

Environmental Protection Biodiversity
- “fragment habitat, introduce disturbance, and eliminate roadless character”
- “destroy wildlife habitat”
- “jeopardizes 44.5 million acres of undeveloped backcountry forestland”
Water Quality Quantity
- “threaten drinking water sources”
Climate Carbon Storage
- “worsen climate change”
- “storing 10.64 Gt CO2e”
- “Paris Agreement compliance and 30x30 targets”
Recreation Tourism Public Use
- “destroy recreation areas”
- “enjoy them as they have stood for generations”
- “quiet, remote, and backcountry recreation values”

What it names

National Forests: Umatilla National Forest
Roadless areas: Jumpoff Joe
Works cited: 10.3389/ffgc.2022.979528

The comment

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

Dear Chief Schultz, Military service builds an understanding of what happens when the rules that govern an institution are treated as optional — the institution's capacity to function depends on those rules being taken seriously — and the Department's proposed rescission does not take the Roadless Area Conservation Rule seriously enough. I live near these areas and get the opportunity to enjoy them as they have stood for generations. Once road open these areas up to industrialization, those areas are gone or altered forever. Opening these areas up with additional roads will only make it easier to justify logging, mining or increased public access which will all permanently damage these protected areas. Regarding the Jumpoff Joe in the Umatilla National Forest, Oregon: New road construction, reconstruction, and associated development fragment habitat, introduce disturbance, and eliminate roadless character. Rescinding the Roadless Rule would open the Jumpoff Joe, Umatilla National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. The proposed rollback of the 2001 Roadless Rule jeopardizes 44.5 million acres of undeveloped backcountry forestland managed by the U.S. Forest Service. These forests have only remained intact because of the Forest Service's nearly 25-year-old commitment not to build roads in these areas for harmful activities like major logging operations or oil-and-gas drilling. The Federal Register Notice initiating the rescission states the goal explicitly: to "facilitate domestic production" of "timber, energy and mineral production... to the maximum possible extent." The proposal is being advanced under Executive Orders 14192 (deregulation), 14225 (timber expansion), and 14154 (energy unleashing), and follows other administrative actions calling for a dramatic increase in logging and oil and gas drilling on federal lands. An increase in these industrial activities would worsen climate change, destroy recreation areas, put the lands at greater risk of wildfire, destroy wildlife habitat, and threaten drinking water sources. Building more roads in national forests would be a drain on taxpayers. Even with the Roadless Rule in place, the Forest Service already has a 380,000-mile road system—twice as long as the U.S. highway system—crisscrossing national forests. The agency cannot afford to maintain it: the deferred-maintenance road backlog was estimated at $8.4 billion in the 2001 Final Environmental Impact Statement and is roughly $15.6 billion in today's dollars. The Government Accountability Office has repeatedly flagged Forest Service deferred maintenance as one of the largest in the federal government, and the backlog has never dropped below $5 billion. Adding new roads to inventoried roadless areas would only deepen that hole. The Roadless Rule is one of America's most popular conservation measures, and that support has not faded. Prior to its 2001 enactment, more than 600 public hearings were held nationwide and 1.6 million Americans weighed in to call for protection of these forestlands—more comments than any other federal rule had received at the time. When USDA announced its rescission proposal, the compressed 21-day public comment period in late 2025 drew approximately 600,000 additional comments. A detailed roadless.org analysis of the comment record found that more than 99.8% of submitters opposed the rescission. A February 2026 Pew Charitable Trusts national poll found that 76% of likely voters support the Roadless Rule compared to just 13% opposed, with bipartisan backing from 71% of Republicans, 80% of Democrats, and 80% of independents. More than 100 members of Congress have co-sponsored the Roadless Area Conservation Act of 2025 (S.2042 / H.R.3930) to codify the Rule so it could not be rolled back without an act of Congress. “Maps mature and old-growth (MOG) forests across the conterminous U.S. using LiDAR-derived structural metrics. Finds 76% of MOG on federal lands (storing 10.64 Gt CO2e) is vulnerable to logging. Recommends elevating the conservation status of Inventoried Roadless Areas as a key step toward Paris Agreement compliance and 30x30 targets. — DellaSala et al., 2022 (https://doi.org/10.3389/ffgc.2022.979528)” Changing the rules on road access is not for the benefit of the protected areas, it is a benefit to the rich and greedy. Do your job and protect the lands you are tasked with protecting. Very truly yours, CommentID: RLC-20260913-N2L28I