Comment Analysis · Docket FS-2025-0001

FS-2025-0001-528571

Opposes rescissionA2 moderateSubstance 16/24Owed an answerPosted October 1, 2026 On Regulations.gov

In short: The comment documents specific deficiencies in the agency's analysis regarding small business impacts, reliance interests, wildfire ignition density, and sediment delivery to municipal water intakes, citing specific data from the DEIS and requesting quantification of these impacts.

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

A2 moderate: Hard to dismiss — it shows cause and effect.

Owed an answer on Analytical gap, Evidence.

Standard dismissals it defeats

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.

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.
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.
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

Recreation Tourism Public Use
- “Hiking and camping in roadless areas”
- “places I love to paddle”
- “navigating into the wilderness without the convenience of destructive roads”
- “lost recreation benefit at a minimum of $6.1 million a year”
Water Quality Quantity
- “improved water and air quality”
- “supplies roughly 60 percent of Bend's municipal drinking water”
- “main cause of soil erosion”
- “quantify projected sediment delivery to the municipal intakes”
Environmental Protection Biodiversity
- “world with more wildlife and biodiversity”
- “federally threatened bull trout, Oregon spotted frog, northern spotted owl”
- “habitat a surge in human-caused fire could degrade”
- “old-growth forest”
Legal Regulatory Framework
- “small-business analysis cannot be squared with its own cost figures”
- “withdraw the certification and conduct a genuine assessment”
- “declined to weigh them”
- “identify and weigh the reliance interests”

What it names

Roadless areas: Green MountainLookout Mountain

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Growing up on the East Coast, I had no real sense of what public lands could be until I lived in Oregon for a year. Hiking and camping in roadless areas of the Deschutes and Ochoco National Forests, places like Lookout Mountain, Tumalo Mountain, Green Mountain, and Cascade Lakes, showed me what it means to have natural spaces where dispersed recreation is inevitable and prevents the overburdening of human activity. Beyond hiking and camping, Roadless Areas help protect the availability and quality of places I love to paddle too, including many alpine lakes and Wild and Scenic Rivers, like the Rogue, the Crooked, and the Deschutes. I want to return to these places someday with my children, so they can experience the reward of navigating into the wilderness without the convenience of destructive roads. Repealing the Roadless Rule will take us multiple steps back from my vision of natural spaces and world with more wildlife and biodiversity, improved water and air quality, and a more stable climate for future generations. I oppose rescission for the reasons that follow. The agency's small-business analysis cannot be squared with its own cost figures. "The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year." That conclusion is reached by spreading the loss across every small firm in the sector nationally rather than examining the outfitters and guides who actually hold permits in the affected areas. The Deschutes alone holds 11 inventoried roadless areas totaling 136,446 acres, and Oregon holds 211 inventoried roadless areas totaling 1,937,741 acres. The operators whose livelihoods depend on those specific landscapes are the ones the analysis should assess. I ask that the agency withdraw the certification and conduct a genuine assessment of the small entities actually operating in the potentially affected roadless areas, not the national average firm. The agency has also invited comment on reliance interests and then declined to weigh them. "The proposal solicits 'any reliance interests in the current rule that could be affected by this proposal' (91 FR 53830-31), and the Cost Benefit Analysis weighs none." This comment is one such interest. I built expectations around these places, and around the idea of returning to them with my children, on the reasonable assumption that the protections the rule provides would hold. An agency changing course is obliged to identify and weigh the reliance interests its prior policy created. The agency should identify and weigh the reliance interests described in the comments it receives, including this one. The agency's own fire data argues against the proposal. "Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads." The Deschutes supports federally threatened bull trout, Oregon spotted frog, northern spotted owl, white-headed woodpecker, redband trout, and elk, all species whose habitat a surge in human-caused fire could degrade. The effects analysis concedes that road access could increase the number and frequency of wildfires, yet projects no numbers from that concession. The agency must quantify the expected increase in human-caused ignitions from new road access and weigh it against whatever wildfire hazard reduction it claims to offer. Water is the issue that closes this letter, because Bridge Creek, running through old-growth forest on the Deschutes, supplies roughly 60 percent of Bend's municipal drinking water, and across the Pacific Northwest region 1,522 municipal water intakes sit in watersheds containing affected roadless areas. The document the agency relies upon 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 record. No projection of what it means for downstream intakes follows it. The agency has not told the public what sediment load those intakes should expect if roadless protections are lifted. That omission is not a minor gap. The agency must quantify projected sediment delivery to the municipal intakes downstream of these areas before this proposal advances any further. Sincerely, Taylor Wilkie Warsaw, NY