Comment Analysis · Docket FS-2025-0001

FS-2025-0001-547590

Opposes rescissionA1 strongSubstance 14/24Owed an answerPosted October 4, 2026 On Regulations.gov

In short: The comment documents specific deficiencies in the agency's analysis by citing the agency's own record regarding elk, deer, and bear impacts, wildfire ignition data (DEIS Table 21), economic costs, and water quality, while requesting explanations for how the rescission reconciles with these findings and prior legal holdings.

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, 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

Wildlife Habitat
- “These places shelter bears, elk, and deer”
- “elk survival rates rose during a road closure”
- “roads built for extraction may have altered mule deer migration routes”
- “increased contact and conflict that come with open roads in grizzly habitat”
Water Quality Quantity
- “1,522 municipal water intakes sit in watersheds containing affected roadless areas”
- “roads and their facilities can produce up to 90 percent of the sediment”
- “Preserving these fragile ecosystems is necessary for clean water”
- “how rescission protects drinking water downstream”
Recreation Tourism Public Use
- “We visit for the beauty, peacefulness, uninterrupted landscapes”
- “A road is noise and sight pollution to ALL”
- “We paddle lakes, rivers and streams”
- “Silver Creek is good therapy near a heavier population”
Forest Management Wildfire
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires”
- “far higher fire density on roaded land than inside the affected roadless areas”
- “The proposal invokes wildfire and fuels management as a reason to rescind”

What it names

National Forests: Deschutes National Forest Ochoco National Forest
Roadless areas: Green MountainLookout MountainNorth PaulinaRock CreekSilver CreekSouth Paulina
Law cited: 28 U.S.C. Section 1291

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 My family explores the Cascade corridor from Mount Baker to the Sierra. We paddle lakes, rivers and streams. We photograph everything we encounter on our adventures. We visit for the beauty, peacefulness, uninterrupted landscapes, and the flora and fauna. A road is noise and sight pollution to ALL! I oppose rescinding the 2001 Roadless Area Conservation Rule. We have visited Rock Creek in the Ochoco National Forest and its beautiful watershed. We explore South Paulina in the Deschutes National Forest for the beauty. We have hiked Lookout Mountain, since the early 2000s. North Paulina is beautiful, and our family has enjoyed exploring it for years. The birding at Green Mountain is phenomenal, and would be devastating to lose those creatures. Silver Creek is good therapy near a heavier population, and that matters too. These places shelter bears, elk, and deer. On elk, the agency's own cited research found that elk survival rates rose during a road closure and fell again when the gates were removed. Elk avoid areas near roads and the agency's own analysis says ideal summer elk habitat is unroaded land with cover and forage. On deer, the agency's own record cites research finding that roads built for extraction may have altered mule deer migration routes and increased their movement speed. Roads disrupt migration and eliminate the unroaded security deer depend on. On bears, the agency's own citation from the federal grizzly recovery plan states that the increased contact and conflict that come with open roads in grizzly habitat can ultimately end in grizzly mortality, and shooting, habituation and food reward all increase with the use of even secondary unpaved roads. I ask that the agency explain in this docket how rescinding the rule can be squared with each of those specific findings in its own record. The agency's own record states that "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal invokes wildfire and fuels management as a reason to rescind. That reasoning contradicts the agency's own ignition data. The agency must explain why it departs from those findings and reconcile this proposal with DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. I am also not persuaded that the economics favor this action. The agency's own record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency should reconcile the proposal with its own cost-benefit analysis, which cannot establish a net benefit, and explain how expanding a road system already carrying a $6.9 billion maintenance backlog makes sense when the existing roads already need fixing. Why not pay to fix the current roads and avoid more debt? Oregon holds 211 inventoried roadless areas totaling 1,937,741 acres, and across the Pacific Northwest region 1,522 municipal water intakes sit in watersheds containing affected roadless areas. The agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Preserving these fragile ecosystems is necessary for clean water in our future. The agency must answer, directly and specifically, how rescission protects drinking water downstream from the roadless areas we have walked and paddled. The agency has already tried replacing this national rule with a state-by-state approach. Its own record acknowledges that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The Ninth Circuit rejected that approach. The agency must explain how this proposal avoids the same deficiencies. On the question of statutory authority, the Tenth Circuit held: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The agency must address that holding and state the basis for any contrary position it now takes. The Forest Service held more than 600 public meetings and took 1.6 million comments to write this rule. It has held none to undo it. Future generations should not inherit fewer of these places than we did. Public land should be a safe and sheltered place from human exploitation. These places should be kept whole.