Comment Analysis · Docket FS-2025-0001

FS-2025-0001-466899

Opposes rescissionA1 strongSubstance 16/24Owed an answerPosted September 22, 2026 On Regulations.gov

In short: The comment establishes that the agency's analysis fails to reconcile contradictory economic data, adequately explain departures from prior factual findings under the APA, or address specific regional impacts on water quality, tribal rights, and wildfire risks, while requesting the retention of the 2001 Roadless Area Conservation Rule.

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, Alternative, 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

Legal Regulatory Framework
- “Organized Village of Kake v. U.S. Department of Agriculture”
- “violated the Administrative Procedure Act”
- “contradicting material findings supporting an earlier Roadless Rule decision”
- “identify and explain the changes”
Environmental Protection Biodiversity
- “wildlife corridor, or ecological connection”
- “fragmentation, invasive species, watershed alteration”
- “salmonid habitat, mature and old forest”
- “habitat connectivity”
Water Quality Quantity
- “40 percent of Pacific Northwest surface waters in the affected analysis are impaired”
- “regional consequences for water supplies”
- “water quality”
- “watershed alteration”
Tribal Sovereignty
- “majority sentiment among consulted Tribal governments opposed rescission”
- “Concerns included sovereignty, cultural sites”
- “traditional foods, water quality, subsistence resources”
- “address those concerns at the same policy scale”

What it names

Roadless areas: Three Sisters
Law cited: 795 F.3d 956

The comment

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

Dear Secretary Rollins and Chief Schultz: I oppose rescission of the 2001 Roadless Area Conservation Rule. I live in Oregon’s McKenzie River Valley and spend substantial time in western Oregon’s national forests hiking, studying and propagating native plants, and participating in trail work. My family survived the 2020 Holiday Farm Fire, but we lost our home and forest. Wildfire, forest resilience, roads, and water are concrete matters to me. Three Sisters Wilderness is one of the places I value most. I understand that rescission would not remove its statutory Wilderness protection. It nevertheless taught me the value of undeveloped lands surrounding and connecting protected places. Wilderness boundaries do not encompass every headwater, wildlife corridor, or ecological connection supporting the Cascade landscape. The Roadless Rule has limited road construction, reconstruction, and timber harvest in inventoried roadless areas for approximately twenty-five years. USDA now cites changed conditions, improved forest planning, and different policy priorities. To the extent its decision relies on factual findings contradicting those underlying the 2001 Rule, USDA should identify and explain the changes. In Organized Village of Kake v. U.S. Department of Agriculture, 795 F.3d 956 (9th Cir. 2015) (en banc), the Ninth Circuit held that USDA violated the Administrative Procedure Act by contradicting material findings supporting an earlier Roadless Rule decision without adequately explaining its departure. I support scientifically justified work that protects communities and improves ecosystem resilience. I do not accept that removing national protections from 44.7 million acres necessarily improves wildfire safety. USDA recognizes that roads may facilitate treatment and response but may also increase human-caused ignitions. Its analysis says high road-building costs and declining budgets mean the overall increase in treatment capacity would likely be modest. The existing Rule already permits roads needed to address imminent threats to public health and safety from fire or other catastrophic events and specified tree-cutting for restoration and reducing uncharacteristic wildfire effects. USDA should identify deficiencies in these exceptions and explain why targeted amendments could not address them with fewer consequences than nationwide rescission. I do not support Alternative 3. USDA estimates it would remove Roadless Rule designation and prohibitions from 31.7 million of the 44.7 million acres currently governed by the national Rule, retaining about 13 million acres. I mention it only because USDA itself identified approaches less sweeping than complete rescission. The economic analysis requires clarification. Its table labels $9.9 million to $22 million as annual timber benefits to society, while its narrative describes that amount as industry revenue and estimates producer surplus at $4.6 million to $10.6 million. USDA should reconcile those descriptions. USDA estimates that keeping existing roads and bridges in good repair would require $1.6 billion annually, compared with $270 million in FY2023 funding. Annual maintenance is estimated at $5,000 to $50,000 per mile. USDA should disclose expected additional mileage, funding, maintenance responsibility, backlog effects, and decommissioning costs—or explain how those uncertainties were considered. USDA says rescission would not itself authorize a particular road or timber sale, but it also identifies additional road construction and timber harvest as reasonably foreseeable. Later project review cannot recreate the national standard after rescission. The final analysis should address fragmentation, invasive species, watershed alteration, recreation settings, and wildlife connectivity. The DEIS reports that 40 percent of Pacific Northwest surface waters in the affected analysis are impaired. USDA should disclose regional consequences for water supplies, salmonid habitat, mature and old forest, wildfire ignitions, and habitat connectivity. The Tribal Summary reports that, as of December 5, 2025, the majority sentiment among consulted Tribal governments opposed rescission. Concerns included sovereignty, cultural sites, traditional foods, water quality, subsistence resources, and repeated project-level review. USDA should explain how consultation affected the proposal and address those concerns at the same policy scale. It should also assess significant reliance interests created during the Rule’s operation. I request that USDA select Alternative 1, No Action, and retain the 2001 Roadless Area Conservation Rule. I do not endorse Alternative 3 as a substitute. Before issuing a final rule, USDA should address prior findings, foreseeable effects, reliance interests, Tribal concerns, costs, and acknowledged uncertainties. Thank you for considering my comments. Respectfully submitted, Ken Rawles Vida, Oregon