Comment Analysis · Docket FS-2025-0001

FS-2025-0001-418350

Opposes rescissionA2 moderateSubstance 14/24Owed an answerPosted September 16, 2026 On Regulations.gov

In short: The comment documents that the agency's elimination of an alternative allowing temporary roads and timber harvest was based on a circular rationale, and that the economic analysis fails to model local mill capacity or compare timber gains against recreation losses recorded in Table 49, while specifically identifying the Willamette National Forest and its roadless areas as the affected location.

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

A2 moderate: Hard to dismiss — it shows cause and effect.

Owed an answer on Analytical gap.

Standard dismissals it defeats

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.

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.
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.
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

Governance Policy Process
- “The agency eliminated from detailed study an alternative that would have kept inventoried roadless area boundaries”
- “That rationale is circular”
- “The purpose and need was written to require deregulation”
- “must consider adding such an alternative to the detailed study range”
Economic Impact Fiscal
- “The economic picture presented is also incomplete”
- “analysis does not model whether local mill capacity and timber markets can actually absorb that increase”
- “no offsetting analysis compares those figures against projected timber-sector gains”
- “provide a net economic analysis that quantifies projected gains from increased timber harvest against projected losses to recreation-dependent businesses”
Environmental Protection Biodiversity
- “studying wildflowers, rare plants, birds, mushrooms, lichens, and old-growth forests”
- “opens these precious areas to more erosion, invasive species, and fire risk from human activities”
- “The Roadless Rule has been a key bulwark to protecting some of our most precious public lands”
Recreation Tourism Public Use
- “I have hiked and studied in many Roadless Areas”
- “I guide nature walks in the Coast Range and around Corvallis”
- “I hike Echo Mountain, Iron Mountain, and the Mount Jefferson Wilderness with family and friends”
- “recreation expenditures at stake are substantial”

What it names

National Forests: Willamette National Forest
Roadless areas: Echo Mountain

The comment

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

Dear Secretary Brooke Rollins, My name is Sunia Yang and I live in Corvallis, Oregon. I strongly oppose the USDAs proposal to eliminate or weaken the Roadless Rule. I have hiked and studied in many Roadless Areas in Oregon, Alaska, California and Utah. I guide nature walks in the Coast Range and around Corvallis. The roadless areas of the Willamette National Forest are places I know from the ground up. I hike Echo Mountain, Iron Mountain, and the Mount Jefferson Wilderness with family and friends, studying wildflowers, rare plants, birds, mushrooms, lichens, and old-growth forests. What USDA is now proposing, rescinding the 2001 Roadless Rule, would open those landscapes to road construction and timber harvest without the national-level protections that have held since 2001. I oppose this rescission and ask the agency to address the following points before issuing any final rule. The agency eliminated from detailed study an alternative that would have kept inventoried roadless area boundaries and prohibitions on permanent road construction while allowing temporary roads and timber harvest. Its stated reason was that this option was not responsive to the purpose and need. That rationale is circular. As documented in the Alternatives Considered but Eliminated from Detailed Study section, "An alternative that considered maintaining existing inventoried roadless area boundaries and prohibitions on permanent road construction while allowing temporary road construction and timber harvest was considered but eliminated from detailed study as not being responsive to the purpose and need." The purpose and need was written to require deregulation, so any option that keeps meaningful protections is defined out of existence before analysis begins. The agency must explain in non-circular terms why an alternative relying on temporary roads for hazardous fuel treatment and selective harvest inside roadless areas cannot meet its stated fire and forest-health objectives, and must consider adding such an alternative to the detailed study range. The economic picture presented is also incomplete. Alternatives 2 and 3 are projected to increase total National Forest System sawtimber harvest, yet the analysis does not model whether local mill capacity and timber markets can actually absorb that increase, nor does it estimate net job creation against recreation-economy losses. The recreation expenditures at stake are substantial. The document records, in Table 49, expenditures within 50 miles of recreation destinations by visitors to the non-Wilderness dispersed areas, including inventoried roadless areas, of national forests potentially affected by the roadless rule rescission, yet no offsetting analysis compares those figures against projected timber-sector gains. I hike these lands; I watch wildlife here; I care how my tax dollars are spent managing them. The agency should provide a net economic analysis that quantifies projected gains from increased timber harvest against projected losses to recreation-dependent businesses before the final rule is issued. Opening the roadless areas also opens these precious areas to more erosion, invasive species, and fire risk from human activities. The Roadless Rule has been a key bulwark to protecting some of our most precious public lands. I urge the USDA to select Alternative 1 and abandon any effort to weaken the Roadless Rule. Sincerely, Sunia Yang