Comment Analysis · Docket FS-2025-0001

FS-2025-0001-571424

Opposes rescissionA2 moderateSubstance 11/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment establishes that the agency's proposed rescission of the 2001 Roadless Rule contains internal contradictions regarding forest health impacts, relies on an inadequate one-year economic ceiling for recreation losses, and fails to provide specific safeguards or analysis for the 65-79% of operable land that consists of old-growth and mature forest.

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.

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

Environmental Protection Biodiversity
- “last remaining old-growth forest east of the Cascades”
- “Old ponderosa pine, Douglas fir and western larch”
- “no old-growth-specific safeguards”
- “Old and mature stands together make up the overwhelming majority”
Recreation Tourism Public Use
- “I hike and camp in them”
- “threatens what makes them worth entering”
- “dispersed, roadless country this analysis inadequately captures”
- “wildlife-related recreation”
Governance Policy Process
- “The agency cannot have it both ways”
- “The agency must reconcile the forest health rationale”
- “The Forest Service must separately analyze and publicly disclose”
- “The document as written does not do that”
Economic Impact Fiscal
- “economic case for rescission is also thinner than presented”
- “potential annual losses for trail and dispersed area recreation”
- “estimate cumulative recreation losses over 20 years”
- “compare them with projected timber revenue”

What it names

Roadless areas: Joseph CanyonPonderosa Pine

The comment

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

The Wallowas, Joseph Canyon, the upper John Day, the deep river country draining toward the Snake. Old ponderosa pine, Douglas fir and western larch that survived generations of logging and now stand in some of the last remaining old-growth forest east of the Cascades. These are some of Oregon's great forests, and I hike and camp in them. The proposed rescission of the 2001 Roadless Area Conservation Rule threatens what makes them worth entering. The agency's stated rationale for rescission includes forest health, but its own document undercuts that rationale. The notice claims that "The 2001 Roadless Rule limited the Forest Service's ability to conduct vegetation management within inventoried roadless areas and has contributed to the lack of active management of the national forests, which has contributed to challenges in addressing forest health concerns," as stated in the Rationale for the Proposed Rule. Yet the same document cites research finding the rule did not meaningfully constrain fuel treatments as a share of forested land, and notes that insect and disease risk in western roadless areas is similar to or lower than on managed forest land. The agency cannot have it both ways: either the rule was a meaningful barrier to addressing forest health or it was not. The agency must reconcile the forest health rationale with those internal findings before this rule proceeds. The economic case for rescission is also thinner than presented. The document estimates, in the section on Economic Benefits from Recreation in Roadless Area Forests, that "Assuming an upper limit of a 1 percent annual loss of economic benefit within the likely operable and likely operable but complex areas translates into potential annual losses for trail and dispersed area recreation of $4.8 million and $1.3 million for wildlife-related recreation, nationally." That single-year ceiling is set against roadless recreation benefits of upwards of $1.5 billion, and the document itself concedes that the magnitude of losses is unknown. Roads and changed recreation settings accumulate and persist across decades, not just a single year, and the Recreation section acknowledges that roughly 52 percent of three setting classes are more likely to be affected. The place I hike and camp in is exactly the kind of dispersed, roadless country this analysis inadequately captures. The agency should estimate cumulative recreation losses over 20 years as roads and settings change permanently, and compare them with projected timber revenue, rather than relying on a one-year 1 percent ceiling as though roads can be unbuilt. Most pressing is what the document discloses about the land that would actually be opened to harvest. In the section on Implications for Forest Vegetation, Health, and Carbon, the agency's own data state that "approximately 11-16 percent is old-growth forest, 54-63 percent is mature forest, and 26-31 percent is young forest" within the operable areas most likely to be logged under the proposed action. Old and mature stands together make up the overwhelming majority of that timberland. The document identifies no old-growth-specific safeguards beyond general land management plan compliance before these stands could be harvested. The forests I walk through east of the Cascades, the ones that survived previous logging rounds, are precisely this kind of old and mature timber. The Forest Service must separately analyze and publicly disclose what protections, if any, would apply specifically to old-growth and mature stands before any harvest is authorized in this land base. The document as written does not do that.