Comment Analysis · Docket FS-2025-0001

FS-2025-0001-456684

Opposes rescissionA0 noneSubstance 5/24Posted September 21, 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

Wildlife Habitat
- “wildlife populations would be threatened”
- “adversely affect 327 threatened and endangered species”
- “more loss to critical, already threatened and endangered wildlife populations”
- “rights of non-human life, and their homes must be protected”
Water Quality Quantity
- “jeopardizing access to drinking water”
- “Molalla will lose protections in their drinking watersheds”
- “sediment delivered to surface waters is a major source of water quality degradation”
- “less secure access to drinking water”
Recreation Tourism Public Use
- “critical sites for recreation that fund local communities through tourist spending”
- “spend just about every weekend going out into public land to spend time in nature”
- “access to conserved lands where we can be outside and connect to nature”
- “quality of my life, and the quality of the lives of our children”
Cultural Heritage Indigenous
- “land that still holds indigenous artifacts and petroglyphs thousands of years old”
- “indigenous artifacts and petroglyphs”

What it names

National Forests: Winema National Forest

The comment

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. This careless decision would wreak havoc on our communities and public lands. The expensive infrastructure backlog would skyrocket, we would be at an increased risk for wildfires while jeopardizing access to drinking water, wildlife populations would be threatened, and critical sites for recreation that fund local communities through tourist spending would be damaged or irradicated. I live in Portland, Oregon, and I spend just about every weekend going out into public land to spend time in nature. I sincerely urge you to take Alternative 1, the No Action alternative, and retain full Roadless Rule protections. Over Labor Day weekend, I travelled to roadless areas in the Warner Valley, Fremont-Winema National Forest, and Newberry Volcanic National Monument. On this trip, I visited land that still holds indigenous artifacts and petroglyphs thousands of years old, in areas struggling for water and designated as extremely at risk for fire. Some roads were closed due to lack of maintenance and increased chance of causing fires by driving on or near the vegetation. The administration admits that building new roads would significantly inflate the deferred maintenance backlog, which is already over $6.9 billion. Not only that, but recent studies have proven that fires are 4 times more likely to start near a road than in a roadless area. While driving through the Fremont-Winema National Forest in the middle of the day, on our way back home from the roadless area, we had to abruptly slow the car twice to avoid hitting both a coyote and a badger. According to the administration's DEIS, eliminating the Roadless Rule would “adversely affect” 327 threatened and endangered species and 71 designated critical habitats for these species. What that translates to is more wildlife on the additional roads, more risk of collisions for cars, and more loss to critical, already threatened and endangered wildlife populations. Already, our roads put these lands at risk: for the wildlife, the access to safe water, and the increased fire danger. It is crucial to my well-being, and the well-being of many others, that we not only have access to conserved lands where we can be outside and connect to nature, but that our home lives are also safe from natural disasters and shortages. I also fundamentally believe in the rights of non-human life, and their homes must be protected. Even from an anthropocentric perspective, harming native wildlife populations erodes our area's resilience to drought, fire, and food shortages. We are already struggling; we do not need to struggle more. I am truly brought to tears imagining what rescinding the Roadless Rule would do to our beloved lands, the quality of my life, and the quality of the lives of our children. In addition, I am getting married next year in Molalla, a town that gets drinking water from the Molalla River (a drinking watershed in roadless areas). By rescinding the Roadless Rule, Molalla will lose protections in their drinking watersheds. The DEIS states that “Road construction and native surface forest roads are the largest source of sediment related to timber harvest operations, and sediment delivered to surface waters is a major source of water quality degradation.” I am already worried about wildfires and smoke during my wedding. I cannot handle these threats worsening in addition to the new concern of less secure access to drinking water. Worse, my coworker, her husband, and her kids live in Molalla. They can't just choose to stop visiting a place that becomes less tenable due to harmful development on currently protected areas. Their lives, homes, and livelihoods are at stake. I would be deeply impacted by both Alternatives 2 and 3 of the draft EIS. Under the agency’s proposal, Alternative 2 would eliminate protections for nearly 2 million acres of wild, public lands in Oregon. Under Alternative 3, 1.4 million acres (nearly 75% of IRA acres in Oregon) would lose protections, including the ones I am listing here. For these reasons, and enough more to write a book, fully or partially rescinding the Roadless Rule under Alternatives 2 and 3 of the draft EIS would be a horrific mistake. I oppose the proposal to rescind or alter the Roadless Rule, and support Alternative 1, the No Action alternative.