Comment Analysis · Docket FS-2025-0001

FS-2025-0001-556135

Opposes rescissionA3 weakSubstance 11/24Owed an answerPosted October 5, 2026 On Regulations.gov

In short: The comment documents that the proposed rescission of the 2001 Roadless Rule is inconsistent with the Mt. Hood 2015 Travel Analysis Report and the FY26 budget elimination of wildfire funding, while citing specific data on wildfire ignition near roads and water quality impacts to request a thorough environmental analysis and a road maintenance plan.

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 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.
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
- “rely on forest watersheds for clean drinking water”
- “Road building undermines these natural filtration systems”
- “threatens millions of Americans' access to safe drinking water”
- “Guarantee that no watersheds will be negatively affected”
Forest Management Wildfire
- “more roads are likely to mean more fires”
- “wildfires are four times more likely to start in roaded areas”
- “The current rule already allows road-building and logging of smaller trees to reduce fire risk”
- “zeroes out funding for Wildland Fire Management”
Environmental Protection Biodiversity
- “natural resource of natural ecosystem restoration and balance”
- “impacts to wildlife and recreation”
- “protecting unroaded areas is essential to the health of ecosystems, fish, wildlife, and native plants”
- “It will not remain in balance if we continue to extract all we can from it”
Public Opinion Support
- “The Roadless Rule is the most popular rule ever implemented in USDA's history”
- “Over 95% of these comments supported keeping roadless protections”
- “75% of Americans support the Roadless Rule, while only 16% oppose it”
- “rescinding the Roadless Rule directly ignores the will of the majority of Americans”

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 placeEA analysisAnalytical gapEvidenceRequest

My name is Hana Francis, I am writing to submit a public comment on the Notice of Intent to rescind the 2001 Roadless Rule. I care deeply about our national forests because it is a natural resource of natural ecosystem restoration and balance. We rely on forest watersheds for clean drinking water, and we and all other life rely on keeping some lands without building roads into them. I strongly oppose rescinding the 2001 Roadless Rule because of its environmental and economic impacts, impacts to wildlife and recreation, and because we depend on the earth to remain in balance. It will not remain in balance if we continue to extract all we can from it. 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. New research shows wildfires are four times more likely to start in roaded areas than in unroaded tracts. 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. Given that the FY26 budget eliminates funding for wildfire suppression and management, USDA cannot claim this rule change is genuinely about mitigating fire risks. National forests provide drinking water to 60 million Americans, including more than 1 million Oregonians who rely on Mt. Hood National Forest. 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. The Forest Service manages more roads than any other federal agency, yet already struggles to maintain them. The national forest system currently carries a $10.8 billion maintenance backlog. The text of the Roadless Rule itself acknowledges that the Forest Service could not maintain its existing road system to safety and environmental standards. That reality has only worsened as budgets continue to shrink. On the local level, Mt. Hood’s 2015 Travel Analysis Report called for decommissioning, not building, roads, citing risks to water quality and aging, unsafe infrastructure. The Forest Service’s FY26 budget slashes agency funding by more than 60%, and zeroes out funding for Wildland Fire Management, the Wildfire Suppression Operations Reserve Fund, and State, Private, and Tribal Forestry. USDA’s stated rationale for rescission—addressing wildfire risk and giving states more decision-making power—rings hollow when no funding is allocated to meet those goals. Forest revenues today come primarily from recreation, not logging. More roads would degrade recreation opportunities, undercutting the agency’s bottom line. 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. 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. Polling confirms this support endures: a Pew Charitable Trusts survey found 75% of Americans support the Roadless Rule, while only 16% oppose it. USDA calls itself “The People’s Department,” but rescinding the Roadless Rule directly ignores the will of the majority of Americans. For all these reasons; public will, economic responsibility, ecological health, fire safety, and clean water, I strongly oppose rescinding the 2001 Roadless Rule. I ask that before moving forward, the agency: Conduct a thorough environmental analysis of roadless areas to assess the impacts of additional road building; Guarantee that no watersheds will be negatively affected by rescission; Develop and share a detailed plan for addressing its existing backlog in road maintenance and repairs; And commit to moving forward with transparency, including a full account of how public comments were considered and concerns addressed. Please protect America’s remaining roadless areas for current and future generations, Hana Francis