Comment Analysis · Docket FS-2025-0001

FS-2025-0001-571414

Opposes rescissionA2 moderateSubstance 14/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment documents that the agency's DEIS data contradicts its wildfire rationale, identifies a gap in the economic impact analysis for specific small entities, and requests that the agency analyze foreseeable plan amendments and reliance interests before proceeding with the rescission.

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

  • Wildlife Habitat
    • “Roads hurt birds”
    • “bird richness declines with road presence”
    • “road-noise experiments... cut bird abundance by over a quarter”
    • “wildlife in them, are what this comment is about”
  • Forest Management Wildfire
    • “Human-caused ignition density is 22.4 fires per million acres per year on roaded... land against 3.0 inside the affected roadless areas”
    • “human-caused ignitions increase in abundance with proximity to roads”
    • “agency claims road access reduces wildfire hazard, but its own numbers point the other way”
  • Recreation Tourism Public Use
    • “where I camp, hike, and photograph land formations”
    • “lost recreation benefit at a minimum of $6.1 million a year”
    • “outfitters, guides and tour operators as affected”
    • “organized my recreation, my photography... around the protection this rule provides”
  • Governance Policy Process
    • “agency cannot simultaneously declare a foreseeable consequence out of scope and ask the public to comment on it”
    • “withdraw the certification and assess the impact on the small entities actually operating”
    • “identify and weigh the reliance interests described in the comments”
    • “urge the agency to withdraw this proposal”

What it names

National Forests
Gifford Pinchot National ForestMt. Hood National Forest

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The forests I care most about sit in the Pacific Northwest. Mt. Hood National Forest, Gifford Pinchot National Forest, and Salmon-Huckleberry National Forest are where I camp, hike, and photograph land formations, plants, trees, rivers, and lakes. I share those photographs with elders and others who cannot get out there themselves. I also watch birds and animals to see how they live and communicate in the wilderness. Those forests, and the wildlife in them, are what this comment is about. I oppose rescinding the 2001 Roadless Area Conservation Rule. Roads hurt birds. The agency's own record acknowledges this directly. The DEIS cites findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. The birds I watch in these forests depend on the quiet that roadless protection provides. Rescission opens the door to road construction in areas where that protection currently holds. I ask the agency to explain on the record why it weighed this documented harm to bird communities as acceptable, and what mitigation it proposes. The agency's own fire data also cuts directly against the rationale offered here. The DEIS reports that 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. I hike and camp in these forests. I have a direct stake in whether they burn. The agency claims road access reduces wildfire hazard, but its own numbers point the other way. I ask that the agency quantify the expected increase in human-caused ignitions from new road access and weigh that increase against any claimed reduction in wildfire hazard, with that analysis made available for public review. The economic certification accompanying this proposal does not hold together. 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. The underlying flexibility analysis reaches its no-impact conclusion by spreading losses across every small firm in the sector nationally, rather than looking at the outfitters and guides who actually hold permits in the affected areas. That is not an assessment of the affected entities. It is an average that obscures the harm to specific businesses. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. Finally, the agency's treatment of future plan amendments is not defensible as analysis. The proposed rule concedes that subsequent land management plan amendments and revisions "could increase the area where timber harvest and road construction would be allowed," declares changes to plans beyond the scope of the proposal, and then requests public comment on them (91 FR 53830). The agency cannot simultaneously declare a foreseeable consequence out of scope and ask the public to comment on it. That is asking commenters to perform the analysis the agency itself declined to do. The forests I visit in the Pacific Northwest could be directly affected by exactly the plan amendments the agency is refusing to evaluate. I ask that the agency analyze the foreseeable plan-amendment scenario, including expanded timber harvest area, as part of this rulemaking action. The proposal also invites comment on reliance interests without ever analyzing 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 have organized my recreation, my photography, and my practice of sharing the wilderness with people who cannot reach it around the protection this rule provides. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before it proceeds further. I urge the agency to withdraw this proposal. Sincerely, Andree Nyary Portland, Oregon

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