Comment Analysis · Docket FS-2025-0001

FS-2025-0001-576878

Opposes rescissionA1 strongSubstance 17/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment documents that the agency's DEIS contains internal contradictions regarding wildfire ignition risks and economic net benefits, fails to project cited biodiversity fragmentation ranges across the full 40.1 million acres of affected environment, and does not quantify permitting burdens outside existing regulatory exceptions, specifically highlighting risks to Hardesty Mountain and 1,522 municipal water intakes in Oregon.

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

A1 strong: Must be answered — it names the law.

Owed an answer on Analytical gap, Evidence, Legal.

Standard dismissals it defeats

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.
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.
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.

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.
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.

Topics

Wildlife Habitat
- “hear the birds and other wildlife”
- “road-noise experiments in a roadless area cut bird abundance by over a quarter”
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
- “habitat that makes quiet possible... is not recoverable”
Water Quality Quantity
- “large areas left for... clean water and air”
- “1,522 municipal water intakes sitting in watersheds containing affected roadless areas”
- “Clean water is one of the necessities of life”
- “Rescission puts those watersheds at risk”
Forest Management Wildfire
- “Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “DEIS Table 21 reports far higher fire density on roaded land”
- “reconcile the rescission with that ignition data”
Economic Impact Fiscal
- “The economic case for rescission is not made”
- “recreation losses of at least $6.1 million a year”
- “net present value spanning -$92 million to +$199 million”
- “road system already carrying a $6.9 billion maintenance backlog”

What it names

National Forests: Umpqua National Forest
Roadless areas: Hardesty Mountain
Law cited: 36 C.F.R. Section 294.12
Works cited: Kroeger et al. 2022

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeEA analysisAnalytical gapRequest

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Roadless means quiet. That is not a small thing. In places like Hardesty Mountain, in the Umpqua National Forest in Oregon, that quiet is the point. It is what makes it possible to actually hear the birds and other wildlife. I love all waters, rivers and mountain lakes included, and I believe our public lands should be managed for true multi-purpose: certain areas for sustainable tree harvest, certain areas for ecologically safe extraction, but large areas left for recreation, for clean water and air, and for all the non-human inhabitants. The 2001 Roadless Area Conservation Rule is one of the few tools we have that holds that line. I oppose its rescission. The agency's own draft environmental impact statement acknowledges what anyone who goes looking for birds already knows. The DEIS cites the finding that "road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely." Bird richness declines with road presence in forested habitat. These are the agency's own cited findings, from Kroeger et al. 2022, McClure et al. 2013, and Ware et al. If the agency rescinds this rule and roads follow, the habitat that makes quiet possible at Hardesty Mountain and across Oregon's 211 inventoried roadless areas totaling 1,937,741 acres is not recoverable on any human timescale. The DEIS also cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent, and yet no projection of that range across the 40.1 million acres of potentially affected environment appears in the record. I ask the agency to apply that cited fragmentation range to the full 40.1 million acres before it takes any final action. The proposal invokes wildfire as a justification for rescission. But the agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." That is the agency's language, not mine. DEIS Table 21 reports far higher fire density on roaded land than inside the affected roadless areas. The agency must explain why the proposal departs from its own prior findings and reconcile the rescission with that ignition data. The economic case for rescission is not made. The agency's own analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year, with a net present value spanning -$92 million to +$199 million. A cost-benefit analysis that cannot establish a net benefit does not justify expanding a road system already carrying a $6.9 billion maintenance backlog. Moreover, the record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." How does an action with those projected stakes, and that degree of economic uncertainty, justify permanent loss across millions of acres? The agency has not answered that question, and it must do so in this proceeding. The permitting burden argument fares no better. The rule as written states that it "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." Exceptions for public health and safety, existing mineral leases, and community wildfire protection already exist inside the rule. The agency has not identified which specific burdens fall outside those existing exceptions, nor has it quantified them. It should do both before the record closes. Oregon has 1,522 municipal water intakes sitting in watersheds containing affected roadless areas across the Pacific Northwest region. Clean water is one of the necessities of life I named, and it is not separable from the lands that filter and protect it. Rescission puts those watersheds at risk. The record must reflect that cost. Sincerely, John Mullen Dexter, Oregon