Comment Analysis · Docket FS-2025-0001

FS-2025-0001-534475

Opposes rescissionA3 weakSubstance 10/24Owed an answerPosted October 4, 2026 On Regulations.gov

In short: The comment documents that the proposed rescission of the Roadless Area Conservation Rule would eliminate protections for specific watersheds and habitats in Oregon, citing DEIS data on economic costs, species impacts, and water quality degradation to argue for the retention of the No Action alternative.

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

A3 weak: Substantive, but easier to set aside.

Owed an answer on 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.
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.
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.
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
- “protects my community's drinking watershed at Bridge Creek”
- “filter and store clean water”
- “sediment delivered to surface waters is a major source of water quality degradation”
- “ensure that these watersheds remain intact and that water sources are not compromised”
Wildlife Habitat
- “provide refuge for vulnerable species”
- “adversely affect 327 threatened and endangered species”
- “71 designated critical habitats for these species”
- “Bull trout, Chinook salmon, Chum salmon, Coho salmon, Marbled murrelet”
Recreation Tourism Public Use
- “recreation opportunities that millions of Americans depend on”
- “hike, camp, fish, forage, and enjoy nature”
- “degrade roadless areas and backcountry access”
- “loss of $9 million in annual visitor spending in local communities”
Economic Impact Fiscal
- “waste taxpayer resources”
- “leaving taxpayers with billions of dollars in long-term maintenance costs”
- “significantly inflate the deferred maintenance backlog”
- “The economics of these attacks on the Roadless Rule simply do not add up”

What it names

National Forests: Ochoco National Forest
Roadless areas: Bend WatershedLookout MountainSouth Paulina

The comment

Dear Secretary Rollins, I strongly oppose the USDA’s proposal to fully or partially rescind the Roadless Area Conservation Rule. This reckless action would devastate our public lands, waste taxpayer resources, and undermine the clean water, wildlife habitat, and recreation opportunities that millions of Americans depend on. I urge the agency to take Alternative 1, the No Action alternative and retain full Roadless Rule protections. I live in Bend, Oregon and spend time recreating in nearby Roadless Areas like Tumalo Mountain, the Cascade Lakes, Lookout Mountain in the Ochoco National Forest, and North and South Paulina in the Newberry Caldera. I also visit other Roadless Areas across Oregon to hike, camp, fish, forage, and enjoy nature. The Tumalo Mountain Roadless Area is especially important to me because it protects my community’s drinking watershed at Bridge Creek. Under the agency’s proposal, Alternative 2 would eliminate protections for nearly 2 million acres of wild, public lands in Oregon. Under Alternative 3, 1.4 million acres (nearly 75% of IRA acres in Oregon) would lose protections, including the ones I listed above. The economics of these attacks on the Roadless Rule simply do not add up. Building new logging 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. According to the DEIS, the Forest Service could build new roads across 18.2 million acres (44.5% of current IRAs) in the short term. This would significantly inflate the deferred maintenance backlog, which is already over $6.9 billion according to the DEIS. Further, the DEIS estimates that eliminating the Roadless Rule would degrade roadless areas and backcountry access to millions of acres, resulting in a loss of $9 million in annual visitor spending in local communities. Beyond the economic folly, the environmental consequences are severe. Roadless forests represent some of the most intact, resilient ecosystems left in our country. They filter and store clean water, provide refuge for vulnerable species, and serve as critical carbon sinks in the fight against climate change. The DEIS states that eliminating the Roadless Rule would “adversely affect” 327 threatened and endangered species and 71 designated critical habitats for these species. In Oregon, this includes listed species such as Bull trout, Chinook salmon, Chum salmon, Coho salmon, Marbled murrelet, Northern spotted owl, Oregon silverspot butterfly, Oregon spotted frog, Sierra Nevada red fox, and steelhead, among others. How would the agency ensure these populations and their habitats aren’t further degraded without protection of the Roadless Rule? The DEIS also states that “Road construction and native surface forest roads are the largest source of sediment related to timber harvest operations, and sediment delivered to surface waters is a major source of water quality degradation.” Bend, Oregon has exceptional water quality, largely due to the protections of the surrounding Tumalo Mountain - Bend Watershed Roadless Area. This Roadless Area would lose protections under both Alternatives 2 and 3. Other communities in Oregon like Eugene, Ashland, and La Grande would also lose protections to their drinking watersheds. How would the agency ensure that these watersheds remain intact and that water sources are not compromised from increased risk of erosion and sedimentation? Once roads and clearcuts fragment these landscapes, the damage is permanent.