Comment Analysis · Docket FS-2025-0001

FS-2025-0001-485095

Opposes rescissionA0 noneSubstance 6/24Posted September 28, 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
- “rely on national forests for drinking water”
- “Intact forests filter my drinking water”
- “Roadless area are important parts of watersheds that supply clean water”
Wildlife Habitat
- “healthy and connected landscapes for the Pacific Northwest's wild species”
- “intact unlogged and undammed streams”
- “All these beings deserve health homes just because they exist”
Climate Carbon Storage
- “Healthy, old-growth forests provide help mitigate and slow climate change”
- “They store carbon”
- “resilient to wildfire than logged over forests”
Economic Impact Fiscal
- “Building new roads in remote backcountry areas is extraordinarily expensive”
- “leaving taxpayers with billions of dollars in long-term maintenance costs”
- “existing road network carries an $8.5+ billion maintenance backlog”

What it names

Roadless areas: Three Sisters

The comment

USDA Secretary Brooke Rollins and Forest Service Chief Tom Schultz, I am writing today in opposition to rescinding or altering the Roadless Area Conservation Rule. I have lived in the Willamette Valley most of my life, have birders and hunters in my family, and am an accomplished botanist. I have spent countless hours in the roadless areas of Oregon, particularly in the Ochocos, Kalmiopsis, and the Mt. Hood areas, enjoying and educating others about the unique plant communities in those areas. One of my fondest memories is a hiking/camping trip with my parents in the Three Sisters area. Waking up to a dusting of snow, I raced out of our tent singing strawberries and snow, strawberries and snow!!! Inventoried Roadless Areas provide valuable benefits to communities and ecosystems that are harmed and destroyed by road building. - Drinking water: I am one of millions in our country who rely on national forests for drinking water. Intact forests filter my drinking water, ensuring it is clean and safe. Roadless area are important parts of watersheds that supply clean water to many of us. - Wildfire risk: Roadless areas help protect Oregon communities from wildfires because wildfires are far more likely to start near roads and roughly 90% of wildfires are human caused and start within half a mile of a road. These facts contradict one of the administration’s stated rationales for rescinding the roadless rule. - Wildlife habitat: Roadless areas with intact unlogged and undammed streams provide healthy and connected landscapes for the Pacific Northwest’s wild species including, salmon, trout, elk, bear, frogs, countless birds, dragonflies, and more. All these beings deserve health homes just because they exist. They also nourish our souls, carry cultural significance, and literally feed many people, including my family when I was a child. They contribute to our well-being in ways, some obvious, and others we may only realize if we allow them to perish. - Protection from climate change: Healthy, old-growth forests provide help mitigate and slow climate change. They store carbon. And healthy forests with their mixture of ancient, young, and dead trees, are far more resilient to wildfire than logged over forests. - Roads are costly. Building new roads in remote backcountry areas is extraordinarily expensive, leaving taxpayers with billions of dollars in long-term maintenance costs for roads that are rarely, if ever, used. The existing road network carries an $8.5+ billion maintenance backlog. Please don’t expand the roads in our forests; instead reduce them. For all these reasons I ask you to keep the Roadless Rule in place as it is. Thank you.