Comment Analysis · Docket FS-2025-0001

FS-2025-0001-466568

Opposes rescissionA1 strongSubstance 15/24Owed an answerPosted September 22, 2026 On Regulations.gov

In short: The comment establishes that the agency's DEIS contains internal contradictions regarding wildfire ignition data and cost-benefit analysis, fails to quantify sediment delivery to over 7,000 municipal water intakes, and lacks specific enforceable provisions to protect water quality and wildlife in named Oregon 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

A1 strong: Must be answered — it names the law.

Owed an answer on Analytical gap, Evidence, Legal.

Standard dismissals it defeats

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.
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.
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.

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.
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.

Topics

Water Quality Quantity
- “streams in the Siuslaw, Willamette, Umpqua, and Deschutes National Forests degrade”
- “skid roads, trails, log landings and similar disturbances within timber sale areas are the main cause of soil erosion”
- “supplies roughly 60 percent of Bend's municipal drinking water”
- “quantify projected sediment delivery to the more than 7,000 municipal intakes”
Wildlife Habitat
- “birded roadless areas for decades because the birds there are more uncommon”
- “supports one of only two national strongholds for federally threatened bull trout”
- “road-noise experiments in a roadless area cut bird abundance by over a quarter”
- “protect the species that depend on it”
Forest Management Wildfire
- “Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “The proposal nonetheless invokes wildfire management as a justification for rescission”
- “explain in plain terms why its own findings on fire density do not cut against the action”
Recreation Tourism Public Use
- “I have backpacked in almost all of Oregon's National Forests”
- “recreation losses of at least $6.1 million a year”
- “Hardesty Mountain area in the Umpqua, where I have hiked for decades”
- “Kalmiopsis areas in the Siskiyou, which I consider the wildest and most climate-vulnerable landscape”

What it names

Roadless areas: Hardesty MountainMaiden Peak
Law cited: 36 CFR 294.12

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequestAlternativeLegal

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Over fifty-five years of fishing Oregon's rivers, I have watched streams in the Siuslaw, Willamette, Umpqua, and Deschutes National Forests degrade under pressure from excessive logging. I have backpacked in almost all of Oregon's National Forests. I have birded roadless areas for decades because the birds there are more uncommon, and I have now seen over 600 species. I saw my first wolf in the Kalmiopsis. These places are not abstractions to me, and I am filing this comment to oppose rescission of the 2001 Roadless Area Conservation Rule. The agency's own draft environmental impact statement records that "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal nonetheless invokes wildfire management as a justification for rescission. The agency must reconcile that ignition data, found in DEIS Table 21, with its claimed rationale, and explain in plain terms why its own findings on fire density do not cut against the action it is now proposing. The economic case fares no better on its own terms. The agency's record states plainly that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against those figures, the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year, recreation losses of at least $6.1 million a year, and a net present value ranging from -$92 million to +$199 million. That range cannot establish a net benefit. It also cannot justify expanding a road system already carrying a $6.9 billion maintenance backlog. The agency should explain directly how this action passes any reasonable cost-benefit threshold. I have fished the Umpqua and the Deschutes long enough to know what road sediment does to a stream. The DEIS acknowledges that "skid roads, trails, log landings and similar disturbances within timber sale areas are the main cause of soil erosion and 'can contribute up to 90 percent of the sediment generated by timber sale activity.'" That number appears in the document and then nothing follows it. No projection of sediment delivery to downstream intakes is offered. Oregon holds 211 inventoried roadless areas totaling 1,937,741 acres, and across the Pacific Northwest region alone, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. The agency should quantify projected sediment delivery to the more than 7,000 municipal intakes downstream of these areas before finalizing any action. The Deschutes roadless areas, including the 26,432-acre Maiden Peak area, sit in a watershed that supplies roughly 60 percent of Bend's municipal drinking water, and the Deschutes also supports one of only two national strongholds for federally threatened bull trout. The DEIS states that "Approximately 24 million people use water originating within the potentially affected roadless areas, through more than 7,000 municipal intakes, and less than 12 percent of these watersheds are currently impaired." The document then asserts that forest plans address municipal water sources, without identifying a single enforceable provision equivalent to 36 CFR 294.12 or 294.13. That assertion does no protective work. The agency should identify, forest by forest, which plan provisions would carry that load. The DEIS also records that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. Birding roadless areas is how I practice my craft. The Hardesty Mountain area in the Umpqua, where I have hiked for decades and which is exceptional for spring wildflowers, and the Kalmiopsis areas in the Siskiyou, which I consider the wildest and most climate-vulnerable landscape in Oregon, exemplify what the rule protects. Public land should be managed for resilience to climate change, to maintain clean water and protect the species that depend on it. This proposal moves in precisely the opposite direction, and the agency has not shown otherwise. Sincerely, David Funk Eugene, Oregon