Comment Analysis · Docket FS-2025-0001

FS-2025-0001-577219

Opposes rescissionPosted October 6, 2026 On Regulations.gov

Not scored for substance: the comment does not clear the floor of substantive signal.

Topics

  • Water Quality Quantity
    • “increase the risk to critical water supplies”
    • “expose those watersheds to sedimentation risk and reduced water quality”
    • “roads and their associated facilities can produce up to 90 percent of the sediment”
    • “put these water resources directly at risk”
  • Forest Management Wildfire
    • “likely to increase wildfire risk, not reduce it”
    • “increased road density is linked to human-caused wildfires”
    • “fires are 4 times more likely to start near a road”
    • “new road access could increase the number and frequency of wildfires”
  • Economic Impact Fiscal
    • “increase financial burden on taxpayers”
    • “significantly inflate the deferred maintenance backlog”
    • “Recreation supports those local economies”
    • “protections that make those forests worth visiting are what make that economic relationship possible”
  • Recreation Tourism Public Use
    • “avid hiker of National Forests”
    • “national forests near me... are where I spend much of my personal time”
    • “gas, food, and lodging I pay for in small towns”
    • “protections that make those forests worth visiting”

What it names

National Forests
Siuslaw National ForestUmpqua National Forest

The comment

My name is Kaitlyn Hanley, I am a scientist and avid hiker of National Forests, in my backyard (the Rogue-River Siskiyou National Forest, Siuslaw National Forest and Umpqua National Forest) and beyond. I oppose the propose rule to fully or partially rescind the Roadless Area Conservation Rule (Roadless Rule). While I can understand why folks may think increasing management flexibility sounds like a good idea, the rescission of this rule would not result in management flexibility but would result in an expansion of the system of roads that already are challenging to manage with limited budgets, increase the risk to critical water supplies local communities rely on and are likely to increase wildfire risk, not reduce it. First, rescinding the Roadless Rule is likely to result in an expansion of road systems into roadless areas which would require construction and routine maintenance that would result in an increase financial burden on taxpayers and Forest Service Staff. Recent reductions in force have reduced the agency by 20%, reducing their capacity to tackle existing deferred maintenance. In fact, the DIES estimates new roads across 18.2 million acres (44.5% of current IRAs) in the short term would significantly inflate the deferred maintenance backlog, which is already over $6.9 billion. This particularly holds true for Forests in coastal Oregon where steep unstable slopes routinely result in road failure. It is also inconsiderate to the municipal towns and cities that rely on roadless areas for their drinking water to expose those watersheds to sedimentation risk and reduced water quality. The agency's own analysis indicates that roads and their associated facilities can produce up to 90 percent of the sediment from a timber sale. Fewer than 12 percent of the relevant watersheds have impaired streams today, and opening these areas to new road construction would put these water resources directly at risk. The agency has not accounted for what that means to the communities downstream, and it should be required to answer for that gap before any final action is taken. Additionally, the agency describes wildfire management, particularly in the WUI as a need to rescind this rule which a false cause and oversimplification of a complex issue. First, fire reduction in the WUI is essential to protecting human life and property, but the WUI is not often proximal to roadless areas. In fact, research has shown reserve lands like roadless areas have limited interaction or ignition risk for wildfire in WUI (Ager et al. 2016). Second, increased road density is linked to human-caused wildfires with recent research finding that fires are 4 times more likely to start near a road than in a roadless area (Applet et al. 2026). Thus new road access could increase the number and frequency of wildfires. The claimed wildfire hazard reduction cannot be evaluated honestly without quantifying what road access adds to ignition risk, and the agency has not done that. It should. Finally, national forests near me and throughout the West are where I spend much of my personal time. The gas, food, and lodging I pay for in small towns along the way is part of how those communities sustain themselves. Recreation supports those local economies, and the protections that make those forests worth visiting are what make that economic relationship possible. Rescinding the 2001 Roadless Area Conservation Rule would unravel those protections and I oppose it. Thank you for considering my comment. Sincerely, Kaitlyn Hanley Coos Bay, Oregon

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