Comment Analysis · Docket FS-2025-0001

FS-2025-0001-417952

Opposes rescissionA0 noneSubstance 7/24Posted September 16, 2026 On Regulations.gov

In short: The comment establishes that rescinding the Roadless Rule on the Umatilla National Forest would not improve fire access or timber economics, would increase human-caused fire risks and litter, and would undermine local resource management decisions made due to limited maintenance 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

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
- “monitoring rare plants in the Blue Mountains”
- “marshes whose creeks and springs again flow”
- “mushrooms and huckleberries have returned”
- “protects them from local radicals who oppose any kind of government restriction”
Forest Management Wildfire
- “Rescinding the Roadless Act will not provide better access to fight fires”
- “These old roads are already reopened as needed for fighting fires”
- “Rescinding would increase the likelihood of fires started by humans”
Water Quality Quantity
- “trampled stream banks put the forest in distress”
- “marshes whose creeks and springs again flow”
- “cattle and sheep access to the high meadows and streams”
Economic Impact Fiscal
- “Not cost effective for FS to build/open and maintain roads for logging companies”
- “Surrounding communities have not been dependent on logging”
- “Forest service lacked the resources to maintain these roads”

What it names

National Forests: Umatilla National Forest

The comment

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

I have lived most of my life around the Umatilla National Forest where logging and grazing took place for about 100 years. Roads were built by Forest Service for logging by corporations and cattle and sheep access to the high meadows and streams. By the 1970s, clearcuts and subsequent regrowth of fire and disease prone species and overgrazing and subsequent invasive species and trampled stream banks put the forest in distress. As grazing and logging declined, hundreds of miles of roads were closed off to vehicular traffic with gates or berms. The forest service lacked the resources to maintain these roads in the service of recreational vehicles. I have been privileged to walk many of these roads over the last 20 years leading wildflower walks, backpacking and monitoring rare plants in the Blue Mountains. The roads now lead to ridges where the terrain has naturally been restored, marshes whose creeks and springs again flow and open slopes where mushrooms and huckleberries have returned. The decision to close off roads was made locally for reason of limited resources to maintain as well as safety concerns for those in vehicles having the ability to go much further than common sense would dictate. Rescinding the Roadless Act will not provide better access to fight fires. These old roads are already reopened as needed for fighting fires. Rescinding would increase the likelihood of fires started by humans, litter and damage to facilities. Nor would it allow for increased timber harvests as existing timber is on steep slopes in remote areas. Not cost effective for FS to build/open and maintain roads for logging companies. Surrounding communities have not been dependent on logging except for personal use (cabins and fences) since 1880s! Monitoring of expanded road use would not be possible as resources to maintain main roads is not available. 2001 Roadless Rule does not constrains responsible officials. It protects them from local radicals who oppose any kind of government restriction. Responding to this year's evolving national priorities under the guise of 'active management' is disingenuous of the USDA to say the least and not in the best interest of our public lands.