Comment Analysis · Docket FS-2025-0001

FS-2025-0001-580108

Opposes rescissionA1 strongSubstance 18/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment establishes that the agency's proposal fails to identify specific administrative burdens not covered by existing exceptions in 36 C.F.R. Section 294.12, ignores reliance interests in the Cost Benefit Analysis, and fails to quantify the expected increase in human-caused ignitions from new road access despite data showing higher ignition density on roaded lands.

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

Recreation Tourism Public Use
- “hiked to Three Fingered Jack, Canyon Creek Meadows, and Wasco Lake”
- “four hours of beauty and peace, away from development, cars, and commerce”
- “That kind of conversation and connection with family would not have happened surrounded by traffic, busy roads, and noise”
- “My family has planned around the existence of this rule”
Legal Regulatory Framework
- “The existing rule already contains the flexibility the agency says it lacks”
- “It generally banned road building subject to limited exceptions”
- “I ask that the agency identify, on the record, which burdens are not already addressed by the rule's existing exceptions”
- “The proposal solicits 'any reliance interests in the current rule that could be affected by this proposal'”
Forest Management Wildfire
- “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”
- “human-caused ignitions increase in abundance with proximity to roads”
- “The agency must quantify the expected increase in human-caused ignitions that would follow from new road access”
- “weigh it against any claimed reduction in wildfire hazard”

What it names

National Forests: Deschutes National Forest
Roadless areas: Canyon Creek
Law cited: 36 C.F.R. Section 294.12

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 This past summer my three sons and I hiked to Three Fingered Jack, Canyon Creek Meadows, and Wasco Lake in the Deschutes National Forest was a gift. A park ranger greeted us at the trailhead, and what followed was four hours of beauty and peace, away from development, cars, and commerce. That kind of conversation and connection with family would not have happened surrounded by traffic, busy roads, and noise. I oppose the proposed rescission of the Roadless Rule, and I support the No Action Alternative. The Deschutes holds 11 inventoried roadless areas totaling 136,446 acres. Oregon holds 211 inventoried roadless areas totaling 1,937,741 acres. The existing rule already contains the flexibility the agency says it lacks. 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). The proposal gestures at permitting and administrative burdens as justification for rescission, but it does not identify which specific burdens fall outside those existing exceptions. I ask that the agency identify, on the record, which burdens are not already addressed by the rule's existing exceptions, including those for public health and safety, existing mineral leases, and community wildfire protection, and that it quantify those burdens with specificity. 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 family has planned around the existence of this rule. The hike to Three Fingered Jack was possible because those 136,446 acres in the Deschutes have remained intact. Finally, the agency's own fire data cuts 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 Deschutes, where my sons and I walked through four hours of undisturbed forest, sits within a region where fire risk is not a hypothetical. The agency must quantify the expected increase in human-caused ignitions that would follow from new road access and weigh it against any claimed reduction in wildfire hazard before this rescission can proceed.