Comment Analysis · Docket FS-2025-0001

FS-2025-0001-432749

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

In short: The comment documents a specific gap in the agency's regulatory flexibility analysis by arguing that the small-business certification contradicts the DEIS's own findings of $6.1 million in lost recreation benefits and $9 million in expenditure losses, and requests a site-specific environmental analysis and an alternative retaining the 2001 Roadless Area Conservation Rule for 13 named roadless areas.

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, Evidence.

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

Wildlife Habitat
- “kill off ecosystems that are already struggling”
- “home to many elk herds, deer herds, bird population, bears”
- “detrimental to the ecosystem of the Mt.Hood National Forest”
Water Quality Quantity
- “It will poison pure waters”
- “Losing our public lands and roadless areas will destroy our forests”
Recreation Tourism Public Use
- “Let the future generations have the opportunity to enjoy the wonder of our public lands”
- “I hike and camp in these areas”
- “small outfitters and guides who work this same country help people like me get out there”
Legal Regulatory Framework
- “I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule”
- “ask that the agency disclose and analyze the site-specific environmental consequences”
- “ask that the agency respond in the record to each of the issues raised”

What it names

National Forests: Deschutes National Forest Gifford Pinchot National Forest Mt. Hood National Forest Willamette National Forest
Roadless areas: Badger CreekBull Of The WoodsMetolius BreaksMt. Hood AdditionsOpal CreekSalmon - HuckleberrySilver StarTwin LakesWind Creek

The comment

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

I have spent my whole life in the national forests in Oregon. My father has spent his whole life in the national forests and so has his father. Losing our public lands and roadless areas will destroy our forests for future generations. It will poison pure waters and kill off ecosystems that are already struggling. Mt.Hood National Forest is land that should not be touched. The areas surrounding our beautiful mountain are not for sale and they are not needing to be logged. Let the future generations have the opportunity to enjoy the wonder of our public lands like we have. The Badger Creek wilderness is land that is home to many elk herds, deer herds, bird population, bears and whatever other species you can think of in Oregon. It is detrimental to the ecosystem of the Mt.Hood National Forest. There is absolutely no reason at all to build roads into the Badger Creek Wilderness. None at all. Please save our public lands I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule, and specifically about these inventoried roadless areas: - Larch (12,961 acres), Mt. Hood NF, Oregon - Salmon - Huckleberry (17,570 acres), Mt. Hood NF, Oregon - Mt. Hood Additions (13,061 acres), Mt. Hood NF, Oregon - Lake (1,327 acres), Mt. Hood NF, Oregon - Wind Creek (5,438 acres), Mt. Hood NF, Oregon - Silver Star (7,779 acres), Gifford Pinchot NF, Washington - Badger Creek (847 acres), Mt. Hood NF, Oregon - Twin Lakes (6,055 acres), Mt. Hood NF, Oregon - Eagle (16,841 acres), Mt. Hood NF, Oregon - Bull Of The Woods (8,843 acres), Mt. Hood NF, Oregon - Opal Creek (5,417 acres), Willamette NF, Oregon - Olallie (7,607 acres), Mt. Hood NF, Oregon - Metolius Breaks (11,141 acres), Deschutes NF, Oregon I ask that the agency disclose and analyze the site-specific environmental consequences of the proposed rescission for each of these areas, including the effects of the road construction and timber harvest it would newly allow. I raise the following issues for the record and ask that the agency respond to each of them: Issue 1: The small-business certification contradicts the analysis beside it I hike and camp in these areas, and the small outfitters and guides who work this same country help people like me get out there. They deserve a real assessment. The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. The supporting regulatory flexibility analysis reaches its no-impact conclusion by spreading the $9 million annual expenditure loss across every small firm in the sector nationally, rather than assessing the outfitters and guides actually holding permits in the affected areas, and concedes some firms may lose these receipts. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule's protections for the areas named above. Where this proposal rests on factual conclusions that differ from the agency's own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record. Sincerely, Karl Wilson Dufur, Oregon