Comment Analysis · Docket FS-2025-0001

FS-2025-0001-582673

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

In short: The comment establishes that the proposed rescission of the Roadless Area Conservation Rule is inconsistent with the agency's own findings on wildfire ignition rates (DEIS Table 21) and economic costs (maintenance deficit vs. revenue), fails to identify specific administrative burdens outside existing exceptions in 36 C.F.R. Section 294.12, and compromises NEPA compliance by dismissing protective alternatives based on deregulatory executive orders rather than forest conditions, specifically threatening water quality in the Bull Run Watershed and 1,522 other municipal intakes.

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, Alternative, 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

Water Quality Quantity
- “vital to the City of Portland's Bull Run Watershed”
- “provides Portland's drinking water”
- “Road construction in areas like Larch introduces sediment, increases runoff, and elevates the risk of contamination”
- “1,522 municipal water intakes sit in watersheds containing affected roadless areas”
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 in DEIS Table 21”
- “documents far higher fire density on roaded land than inside the affected areas”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “recreation losses of at least $6.1 million a year”
- “net present value range spanning -$92 million to +$199 million”
- “agency is already $6.9 billion behind on maintaining the roads it has”
Governance Policy Process
- “alternatives with more protection were dismissed as not responsive to the deregulatory executive orders”
- “A purpose defined as deregulation forecloses exactly the comparison NEPA requires”
- “The agency must restate the purpose and need in terms of actual forest conditions”
- “analyze at least one fully protective alternative before this proceeding closes”

What it names

National Forests: Mt. Hood National Forest
Roadless areas: Larch
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 placeEA analysisAnalytical gapEvidenceRequestAlternativeLegal

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Public lands belong to all Americans, and they should be managed for the enduring health and integrity of those lands and for their many non-destructive benefits to the public, not for the profits of the timber industry. The proposed rescission of the 2001 Roadless Area Conservation Rule fails that standard, and I oppose it without reservation. The agency's own findings on wildfire make the rescission indefensible on its stated justification. The 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." The proposal nonetheless invokes wildfire and fuels management as reasons to open roadless areas to road construction. I ask that the agency explain, in this proceeding, why the proposal departs from these prior findings, and that it reconcile the rescission with the ignition data in DEIS Table 21, which the record shows documents far higher fire density on roaded land than inside the affected areas. The economic case for rescission is no stronger. The agency's own analysis acknowledges 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." Against that modest upside, the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year, recreation losses of at least $6.1 million a year, and a net present value range spanning -$92 million to +$199 million, a range so wide it cannot establish a net benefit at all. The agency is already $6.9 billion behind on maintaining the roads it has, with a road budget of about $73 million a year. My question is direct: are you proposing to continue neglecting existing roads in roaded areas in order to accommodate the timber industry and its shareholders, while the agency's own numbers cannot demonstrate that expanding the road system pays? The agency must reconcile this proposal with its own economic record and explain how an action of uncertain net value justifies deepening a maintenance deficit of that magnitude. The rule the agency proposes to rescind already contains the flexibility it claims to need. The record acknowledges 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)." The proposal rests in part on permitting and administrative burden, yet it does not identify which specific burdens fall outside those existing exceptions, including those covering public health and safety, existing mineral leases, and community wildfire protection. The agency must name those burdens specifically and quantify them. The Larch Roadless Area in Mt. Hood National Forest, Oregon covers 12,961 acres and is vital to the City of Portland's Bull Run Watershed, which provides Portland's drinking water. Across the Pacific Northwest region, 1,522 municipal water intakes sit in watersheds containing affected roadless areas, according to DEIS Table 35. Oregon alone holds 211 inventoried roadless areas totaling 1,937,741 acres. Road construction in areas like Larch introduces sediment, increases runoff, and elevates the risk of contamination to the water supply of a major American city. I ask plainly: is the agency proposing to foul the drinking water of Portland and communities like it throughout the Pacific Northwest, and if not, what enforceable protection replaces the rule for the 1,522 intakes that DEIS Table 35 identifies? Finally, the alternatives analysis is fatally compromised by the way the agency wrote its own purpose. The record reflects that "alternatives with more protection were dismissed as not responsive to the deregulatory executive orders, and the keep-boundaries option was cut because it 'would continue to restrict local decision-making discretion' and because analysing roadless values is 'an administrative and legal burden for the agency.'" A purpose defined as deregulation forecloses exactly the comparison NEPA requires. The agency must restate the purpose and need in terms of actual forest conditions and analyze at least one fully protective alternative before this proceeding closes. Sincerely, Stephenie J. Frederick Portland, Oregon