Comment Analysis · Docket FS-2025-0001

FS-2025-0001-575224

Opposes rescissionA2 moderateSubstance 13/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment documents specific deficiencies in the agency's analysis regarding small entity impacts, reliance interests, wildfire ignition projections, and biodiversity fragmentation calculations, while citing specific data from the DEIS and Cost Benefit Analysis to support requests for further assessment.

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

Environmental Protection Biodiversity
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
- “keep them wild and without human mechanization”
- “Every creature in those forests... faces consequences”
- “destroys pristine areas permanently”
Water Quality Quantity
- “Roads and logging will affect drinking water”
- “cause erosion that sends sediment into streams and lakes”
- “water-supply consequences its own analysis acknowledges”
- “Mt. Hood watershed”
Forest Management Wildfire
- “Human-caused ignition density is 22.4 fires per million acres... against 3.0 inside the affected roadless areas”
- “human-caused ignitions increase in abundance with proximity to roads”
- “road access could raise the number and frequency of wildfires”
- “calculate the expected increase in human-caused ignitions”
Recreation Tourism Public Use
- “serenity of a roadless area calms the soul”
- “places to breathe clean air and step away from noise”
- “lost recreation benefit at a minimum of $6.1 million a year”
- “enjoy pure nature without the interference of human mechanization”

What it names

National Forests: Mt. 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 serenity of a roadless area calms the soul, and living near both the Gifford Pinchot and the Mt. Hood National Forests, near large cities, I understand what it means for urbanites to have places to breathe clean air and step away from noise. I oppose the rescission of the 2001 Roadless Area Conservation Rule and ask that this comment be entered into the record under Docket FS-2025-0001. Being in nature without mechanical noise is something I value deeply. Watching wildlife, from large mammals to tiny insects, allows us to understand the interdependence of all of nature, and that understanding depends on having places left intact enough to show it. The Forest Service should manage roadless areas as they were originally designated: keep them wild and without human mechanization. That designation was made for a purpose, and it was not to make people rich. The agency's own analysis raises a concern I cannot set aside. 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. That certification is reached by spreading losses across every small firm in the sector nationally, rather than examining the outfitters and guides who actually hold permits in the areas at stake. 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. The agency also invites reliance interests and then does nothing with 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. My own reliance on the Gifford Pinchot and the Mt. Hood remaining roadless is exactly the kind of interest the invitation describes. Families across the Pacific Northwest have arranged their relationship to public land around the expectation that these areas stay protected. The agency should identify and weigh the reliance interests described in the comments it receives, including this one. Roads and logging will affect drinking water. They cause erosion that sends sediment into streams and lakes that feed the watershed my drinking water comes from in the Mt. Hood National Forest. The Forest Service's own data is plain on the mechanism. The agency should explain how it reconciles the rescission with the water-supply consequences its own analysis acknowledges, and it should do so with specificity about the Mt. Hood watershed and others like it. On fire, the agency's own numbers argue against the proposal. 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. The effects analysis concedes that road access could raise the number and frequency of wildfires, yet no quantified projection follows. I ask that the agency calculate the expected increase in human-caused ignitions from new road access and weigh it honestly against any claimed reduction in wildfire hazard. The biodiversity data in the DEIS is similarly introduced and then left dangling. The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. That range is stated, and then no projection across the 40.1 million potentially affected acres follows. Every creature in those forests, from the large mammals I described to the insects, faces consequences that the agency has chosen not to calculate. The agency must apply the cited fragmentation range to the 40.1 million acres of potentially affected environment. The Forest Service today does not have the money or the personnel to maintain the roads it already has. Building new roads that will likely be left in poor condition once timber companies are finished with them destroys pristine areas permanently and spends taxpayer dollars doing it. These are the last unroaded third of the national forests. A logged stand grows back. A road does not. Each destruction of these forests by large commercial interests eliminates forever the opportunities of future generations to enjoy what is still untouched. I want my children and grandchildren to be able to continue to enjoy pure nature without the interference of human mechanization. Losing roadless areas would be a huge loss to the people and creatures that live and recreate there, and I expect the agency to answer each of the concerns raised here before it proceeds any further. Sincerely, Anonymous Portland Oregon