Comment Analysis · Docket FS-2025-0001

FS-2025-0001-579212

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

In short: The comment establishes a specific reliance interest in the 2001 Roadless Area Conservation Rule based on decades of use in named areas (Salmon-Huckleberry, Mt. Hood, Deschutes) and documents deficiencies in the agency's analysis regarding water supply risks, wildfire ignition data (citing DEIS Table 21), and economic net benefits (citing the Cost Benefit Analysis).

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

  • Recreation Tourism Public Use
    • “Hiking, camping, exploring, just being in the wilderness”
    • “sanity and well-being”
    • “recreation losses of at least $6.1 million a year”
    • “sanity-saving solitude and deep rejuvenation”
  • Water Quality Quantity
    • “Bend's drinking water”
    • “Bridge Creek... supplies roughly 60 percent of that municipal supply”
    • “1,522 municipal water intakes sit in watersheds containing affected roadless areas”
    • “Opening roadless lands to new road construction puts that water at risk”
  • Wildlife Habitat
    • “federally threatened bull trout”
    • “federally threatened Oregon spotted frog”
    • “old-growth forest”
    • “species populations its own records document”
  • 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”
    • “reconcile the rescission with the ignition data”
    • “far higher fire density on roaded land than inside the affected roadless areas”

What it names

National Forests
Deschutes National ForestMt. Hood National Forest
Roadless areas
Mt. Hood Additions

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 Forty years is a long time to depend on a place for your sanity and well-being, but that is exactly what the Salmon-Huckleberry Wilderness and the broader roadless country of Mt. Hood National Forest have been for me. Hiking, camping, exploring, just being in the wilderness: these are not recreational luxuries but something closer to a requirement. The sense of expansiveness and possibilities that roadless land offers, something that simply does not happen in human-built environments, is what I go looking for with a camera and with my own two feet. I oppose the rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001, and I ask the agency to treat this comment as a statement of reliance on that rule across every one of the inventoried roadless areas I name here, including the 17,570 acres of Salmon-Huckleberry, the 13,061 acres of Mt. Hood Additions, the 16,841 acres of Eagle, and the 136,446 acres in Deschutes National Forest's 11 inventoried roadless areas, among others in Mt. Hood and Gifford Pinchot that I have come to know across more than four decades. I have used Bend's drinking water for more than 25 years. The City of Bend confirms that Bridge Creek, running through old-growth forest on the Deschutes, supplies roughly 60 percent of that municipal supply. Oregon holds 1,937,741 acres across 211 inventoried roadless areas, and across the Pacific Northwest region 1,522 municipal water intakes sit in watersheds containing affected roadless areas. Opening roadless lands to new road construction puts that water at risk. The Deschutes also holds one of only two national strongholds for federally threatened bull trout, and Big Marsh supports possibly the largest monitored population of federally threatened Oregon spotted frog anywhere in its range. These are not abstract values. They are part of a landscape I have returned to for more than 30 years precisely because it remains intact. I ask the agency to explain, with specificity, how rescinding the rule protects the watershed conditions and species populations its own records document in these forests. The proposal invokes wildfire and fuels management as a justification for rescission. 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 finding belongs to the agency, not to its opponents. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence and fuel treatment in roadless areas, and that it reconcile the rescission with the ignition data in its own draft environmental impact statement, DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The economics underlying this proposal do not hold up either. The agency's own record states: "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." Against that, the agency's own Cost Benefit 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. No, that math does not work. That is just crazy. The agency must reconcile this proposal with an economic analysis that cannot establish a net benefit, and it must explain how expanding a road system already carrying a $6.9 billion maintenance backlog serves the public interest when the agency's own road budget runs about $73 million a year. This comment is itself a reliance interest. More than four decades of returning to these landscapes, of depending on them for sanity-saving solitude and deep rejuvenation, constitutes exactly the kind of settled expectation the agency invited comment on and then declined to weigh. The agency must identify and assess those interests in its final analysis. Sincerely, Anonymous Bend OR

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