Comment Analysis · Docket FS-2025-0001

FS-2025-0001-526526

Opposes rescissionA0 noneSubstance 7/24Posted October 1, 2026 On Regulations.gov

In short: The comment documents specific geographic and ecological concerns regarding the impact of rescinding the Roadless Rule on wildlife habitats and water quality in Oregon and Washington, specifically citing the northwestern pond turtle and Mt. Hood National Forest, while asserting that the Confederated Tribes of Warm Springs support the rule due to their ceded lands and reservation bordering the forest.

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
- “safeguard wildlife habitats”
- “northwestern pond turtle”
- “protect habitats for 1,600 at-risk species”
- “threaten wildlife in the Pacific Northwest”
Water Quality Quantity
- “protect clean water”
- “National forests provide drinking water to 60 million Americans”
- “Forested watersheds filter and store water more effectively”
- “threatens millions of Americans' access to safe drinking water”
Forest Management Wildfire
- “more roads are likely to mean more fires”
- “Nearly 85% of wildfires are human-caused”
- “wildfires are four times more likely to start in roaded areas”
- “current rule already allows road-building and logging of smaller trees to reduce fire risk”
Public Opinion Support
- “most popular rule ever implemented in USDA's history”
- “Over 95% of these comments supported keeping roadless protections”
- “77% believe 'conserving national forests and other roadless lands for current/future generations' is paramount”
- “Support for conserving these national forests is broad-based and bipartisan”

What it names

National Forests: Mt. Hood National Forest
Roadless areas: Warm Springs

The comment

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

I strongly oppose rescinding the 2001 Roadless Rule. Roadless forests help safeguard wildlife habitats, protect clean water, prevent human-caused wildfires, and connect ecosystems. I am particularly concerned about how the loss of these protections will impact wildlife in Oregon and Washington, including the northwestern pond turtle, which depends on connected aquatic and upland habitat. Northwestern pond turtles are one of two turtle species native to the Pacific Northwest, and are listed as endangered in Washington and sensitive in Oregon. In addition to our native northwestern pond turtle, roadless areas protect habitats for 1,600 at-risk species. Rescinding the Roadless Rule would threaten wildlife in the Pacific Northwest and undermine decades of conservation wins. The Roadless Rule is essential to the preservation of old-growth forests that are hundreds of years old. The Forest Service was originally founded to protect forests and watersheds from logging and development. As evidenced by Reed, Johnson-Barnard, and Baker (1996), roads fragment the landscape in ways that are even more ecologically harmful than clearcuts. The Forest Service itself stated in the text of the Roadless Rule that conserving roadless areas was critical because road construction and logging were the activities “most likely to harm” the characteristics and values the agency is tasked with protecting. That remains true today. National forests provide drinking water to 60 million Americans, including more than 1 million Oregonians who rely on Mt. Hood National Forest. The 2001 Roadless Rule helps safeguard that clean drinking water. Forested watersheds filter and store water more effectively than developed lands, reducing sediment and pollutants; road building undermines these natural filtration systems and threatens millions of Americans’ access to safe drinking water. Contrary to USDA’s claim that this rescission will help the agency reduce fire risk, more roads are likely to mean more fires. Nearly 85% of wildfires are human-caused, and most ignite within a few hundred feet of roads (2000-2017 data based on Wildland Fire Management Information [WFMI] and U.S. Forest Service Research Data Archive). New research shows wildfires are four times more likely to start in roaded areas than in unroaded tracts (see Aplet, Hartger, and Dietz [2026]). Beyond this, the current rule already allows road-building and logging of smaller trees to reduce fire risk and protect public safety. A full rescission is therefore unnecessary for fire safety. The Roadless Rule is the most popular rule ever implemented in USDA’s history. When it was first proposed in 2001, the Roadless Rule received 1.6 million public comments—more than any rule in U.S. history at that time. Over 95% of these comments supported keeping roadless protections. Polling confirms this support endures. According to the Pew Research Center's 2026 "Update on the ‘Roadless Rule,'" "95% of likely voters think [national forests] are important for protecting clean water sources for communities, and 96% think they are important for providing recreational opportunities such as hiking, camping, hunting, and fishing." A recent poll (conducted by Susquehanna Polling and Research, Inc.) found that, "When it comes to a choice between [the] preservation of national forests and other roadless lands (for outdoor recreation and wildlife habitat), or making roadless lands available for timber harvesting (Q3), 77% believe 'conserving national forests and other roadless lands for current/future generations' is paramount. Only 11% believe '…opening up more roadless lands for timber harvesting and/or mining' should be the priority. Support for conserving these national forests is broad-based and bipartisan, including 80% of self-identified Democrats, 71% of Republicans, and 80% of Independent and unaffiliated voters." Elected officials and Tribes, including the Confederated Tribes of Warm Springs, whose ceded lands include Mt. Hood National Forest and whose reservation still borders that forest, have voiced strong support for the Roadless Rule. The Tribes emphasized that protecting unroaded areas is essential to the health of ecosystems, fish, wildlife, and native plants. USDA calls itself “The People’s Department,” but rescinding the Roadless Rule directly ignores the will of the majority of Americans. With climate change and development already fragmenting ecosystems, rescinding the Roadless Rule would jeopardize some of the last large, undeveloped tracts of land in the U.S. Only 3% of the world’s ecosystems remain intact. We can’t afford to abuse what little remains. I urge the U.S. Department of Agriculture to uphold these protections to our wildlife. Please choose Alternative 1, No Action, to retain the 2001 Roadless Rule and its protections for inventoried roadless areas. Thank you for considering this comment.