Comment Analysis · Docket FS-2025-0001

FS-2025-0001-436436

Opposes rescissionA0 noneSubstance 5/24Posted September 16, 2026 On Regulations.gov

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

  • Water Quality Quantity
    • “Drinking water protection”
    • “Undeveloped, unroaded forest headwaters supply drinking water”
    • “Roads and logging in these areas increase sedimentation and erosion that degrade water quality”
  • Recreation Tourism Public Use
    • “Oregonians hunt, fish, hike, and draw drinking water from”
    • “Hunting, fishing, hiking, camping, and other dispersed recreation remain fully allowed”
    • “Oregon's outdoor recreation economy... depends on the continued existence of large, intact backcountry areas”
  • Legal Regulatory Framework
    • “The rule survived over a decade of litigation”
    • “U.S. Supreme Court declined to hear a mining industry appeal”
    • “cementing it as settled law”
  • Forest Management Wildfire
    • “Building new roads into currently intact forest adds long-term maintenance liabilities”
    • “new roads are also a documented vector for human-caused ignitions”
    • “most wildfires start near roads and points of human access”

What it names

National Forests
Deschutes National ForestOchoco National ForestWillamette National Forest
Roadless areas
Joseph CanyonLookout Mountain

The comment

Public Comment: In Support of Retaining the 2001 Roadless Area Conservation Rule To: U.S. Department of Agriculture / U.S. Forest Service Re: Proposed rescission of the 2001 Roadless Area Conservation Rule From: Scott Emry, Oregon resident I am writing as an Oregonian to urge the Forest Service to withdraw its proposal to rescind the 2001 Roadless Area Conservation Rule and to keep this rule fully in place. Why this matters to Oregon specifically: The Roadless Rule protects nearly 2 million acres of national forest land in Oregon — places like Iron Mountain in the Willamette National Forest, Joseph Canyon in Wallowa County, Tumalo Mountain in Central Oregon, and Lookout Mountain in the Ochoco National Forest. In Central Oregon alone, roughly 200,000 acres would be affected, including about 137,000 acres in the Deschutes National Forest and 61,000 acres in the Ochoco National Forest and Crooked River National Grasslands. These are the backcountry areas around the Cascade Lakes Scenic Byway, Mt. Bachelor, and Mt. Hood that Oregonians hunt, fish, hike, and draw drinking water from. The facts supporting the rule: 1. Scale and process: The rule protects 58.5 million acres of national forest nationwide — roughly a third of the entire National Forest System — and was the product of one of the most extensive public rulemaking processes in U.S. history: 600 public hearings and over 1.6 million public comments were submitted before it was finalized in January 2001. 2. Legal durability: The rule survived over a decade of litigation. In October 2012, the U.S. Supreme Court declined to hear a mining industry appeal after lower courts upheld the rule, cementing it as settled law. 3. Drinking water protection: Undeveloped, unroaded forest headwaters supply drinking water to tens of millions of Americans downstream. Roads and logging in these areas increase sedimentation and erosion that degrade water quality; keeping these areas roadless protects that water at the source. 4. Wildfire and road-maintenance costs: The Forest Service already carries a multi-billion-dollar backlog of deferred maintenance on its existing road system. Building new roads into currently intact forest adds long-term maintenance liabilities and, contrary to some claims, new roads are also a documented vector for human-caused ignitions, since most wildfires start near roads and points of human access. 5. Recreation access is preserved, not reduced: The rule does not close any existing road or trail. Hunting, fishing, hiking, camping, and other dispersed recreation remain fully allowed. Oregon's outdoor recreation economy — a significant contributor to the state's GDP and rural employment — depends on the continued existence of large, intact backcountry areas rather than roaded, developed landscapes. 6. Broad, sustained public and political support: In 2025–2026, more than 600,000 public comments were submitted in response to the current proposal to rescind the rule, with the large majority opposed to weakening it. In Congress, Oregon's own delegation has been active on this issue — Rep. Andrea Salinas introduced the Roadless Area Conservation Act to codify the rule into permanent law, and Sen. Ron Wyden has pushed to preserve it in committee votes. My request: Please withdraw the proposed rescission and retain the 2001 Roadless Area Conservation Rule in full, without state-by-state carve-outs or weakening amendments. Oregon's roadless forests are irreplaceable sources of clean water, wildlife habitat, and recreation opportunity, and the rule protecting them has already withstood the most rigorous public and legal scrutiny of any forest policy in modern history. Thank you for considering my comment. Scott Emry Salem, Oregon September, 16, 2026

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