Comment Analysis · Docket FS-2025-0001

FS-2025-0001-559343

Opposes rescissionA0 noneSubstance 9/24Posted October 5, 2026 On Regulations.gov

In short: The comment documents specific local impacts of rescinding the Roadless Rule on water quality, wildfire risk, and wildlife habitat in named Oregon roadless areas, citing DEIS findings to support the commenter's standing as a resident and user of these lands.

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

Recreation Tourism Public Use
- “regularly recreate on public lands”
- “recreational value would be irreparably harmed”
- “support small businesses along the way”
- “recreational opportunities”
Water Quality Quantity
- “harm wildlife, recreational value and water resources”
- “headwaters of watersheds that supply drinking water”
- “Protecting clean water is vital to our future”
- “sediment delivered to surface waters is a major source of water quality degradation”
Wildlife Habitat
- “The forest supports wildlife”
- “rare coastal dune ecosystem that supports plant species”
- “Western Snowy Plover, federally recognized as threatened”
- “even more valuable to wildlife”
Forest Management Wildfire
- “rescinding the Roadless Area Conservation Rule in whole or in part could increase fire risk”
- “Road density is linked to human-caused wildfires”
- “fires are 4 times more likely to start near a road”
- “adding risk that the hot underbelly of a vehicle... will ignite new fires is unacceptable”

What it names

National Forests: Deschutes National Forest Siuslaw National Forest Willamette National Forest
Roadless areas: TahkenitchThree Sisters

The comment

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

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule of 2001. I am a lifelong Oregonian and currently live in Oregon's southern Willamette Valley. I regularly recreate on public lands, including currently inventoried roadless areas that are protected from roadbuilding and timber harvest under the Roadless Area Conservation Rule. Threemile Lake located in the Tahkenitch Roadless Area of the Siuslaw National Forest is one of my favorite places to hike and bring kids to play on dunes. This area consists of coastal rainforest with ancient sitka spruce trees that have ferns growing way up high in the tree canopy. The forest supports wildlife and is a prime area for finding edible wild mushrooms. Tahkenitch Roadless Area also contains a rare coastal dune ecosystem that supports plant species uniquely adapted to shifting sands and the wet deflation zone. The Western Snowy Plover, federally recognized as threatened, nests on the beach in the area. I am also concerned in addition to potential roadbuilding and logging, rescinding the Roadless Rule would expand motorized corridors in the general area for recreational use impacting wildlife. Tenmile Creek is another roadless area further south which is less accessible to hiking and therefore even more valuable to wildlife. Another vitally important IRA is Iron Mountain in the Willamette National Forest in Lane County. A hiking trail takes you through forest and wildflower meadows that support over 300 native wildflower species. The views to the east are phenomenal and if roads were built and surrounding areas were logged the recreational value would be irreparably harmed. To get there, people travel through the small towns and support small businesses along the way. I also frequent Three Creeks Lake and surrounding areas in Deschutes National Forest adjacent to the Three Sisters Wilderness. Roadbuilding and logging in these areas would harm wildlife, recreational value and water resources. Many of the areas currently protected by the Roadless Area Conservation Rule are near the headwaters of watersheds that supply drinking water to our cities. Protecting clean water is vital to our future. According to the DEIS "inventoried roadless areas typically have good water quality due to limited disturbance,” and “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.” My drinking water comes from watersheds partially within Inventoried Roadless Areas. I am also concerned that rescinding the Roadless Area Conservation Rule in whole or in part could increase fire risk. As the Administration itself states, “Road density is linked to human-caused wildfires, and as the density of roads increases so does the probability, number, and frequency of wildfire ignitions.” Recent studies have found that fires are 4 times more likely to start near a road than in a roadless area. The increasing number of wildfires, size of wildfires and intensity of wildfires is a serious concern in the West and doing anything that increases the probability of human caused fires is unwise. Enough fires start due to lightening during our increasingly long fire season, that adding risk that the hot underbelly of a vehicle or a careless toss of a cigarette butt will ignite new fires is unacceptable. The DEIS states that a key purpose of proposing a rescission of the roadless rule is to have greater local decision-making and reduce regulatory burden. A return to decision-making at the individual national forest level means that concerned citizens like myself would have to track proposed roadbuilding and timber harvest across the state and comment on each project. This would limit the public’s ability to meaningfully weigh in. Entirely local planning and decision-making will not adequately account for public opinion. The result would be an erosion of protections needed to support clean drinking water, wildlife habitat, and recreational opportunities. Consistent nationwide protection measures are critical to protecting these values. For all of the above reasons, I believe that alternatives 2 and 3 of the draft EIS would be a serious mistake. I oppose the proposal to rescind or alter the Roadless Rule and I support “Alternative 1, the No Action alternative." I want the Forest Service to protect forests for the multitude of services they provide to people, wildlife, plants, and water resources. I do not want decisions about our public national forestland to favor the private construction industry and timber industry which would inevitably have a bigger voice at the table. The inventoried roadless areas are national treasurers. We cannot afford to serve private industry interests at the expense of the public interest. I urge the Forest Service to retain the current Roadless Rule under Alternative 1.