Comment Analysis · Docket FS-2025-0001

FS-2025-0001-591361

Opposes rescissionA3 weakSubstance 12/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment establishes that rescinding the Roadless Rule would increase wildfire ignition risks and divert funding from community-adjacent fuel treatments, degrade water quality in the Tumalo Mountain Roadless Area, fragment wildlife habitat, harm the local tourism economy, and was processed with an inadequate 32-day comment period.

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

A3 weak: Substantive, but easier to set aside.

Owed an answer on 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.
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.
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.
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

Forest Management Wildfire
- “evidence says rescission would make me less safe”
- “Public monies need to be spent on fuels reduction, not roads”
- “roads bring ignitions”
- “direct fire funding to fuel treatment adjacent to communities”
Water Quality Quantity
- “Roadless watersheds also protect my community's water”
- “Forest roads are a documented source of fine sediment to streams”
- “Sediment degrades spawning habitat, warms streams, and raises treatment costs”
- “New roads upstream of a municipal water supply would add crossings and culverts that will eventually fail”
Wildlife Habitat
- “Roadless lands protect wildlife”
- “Roads fragment habitat and cut connectivity”
- “elk select habitat away from roads”
- “Rescinding the Roadless Rule will only further threaten this species”
Recreation Tourism Public Use
- “my income depends on guests who come to Central Oregon for its forests, clean air, and outdoor recreation”
- “bookings fell about30% during fire and smoke events”
- “My guests also come for the quiet, undeveloped backcountry the Roadless Rule protects”
- “I specifically live in Central Oregon to hunt, hike, and ride in places where it is still quiet”

The comment

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

To the USDA Forest Service: I live in Tumalo, Central Oregon, between Bend and Sisters. Wildfire threatens my home, my property, and my livelihood. The Forest Service says rescinding the Roadless Rule will help with wildfire. I am writing to urge you to retain the rule in full (Alternative 1), because the evidence says rescission would make me less safe and would not address the real problem. Forest Service Chief Tom Schultz says more than 40% of inventoried roadless areas have high or very high wildfire hazard potential, but that only 5% have received fuels reduction. That gap reflects what treatment is funded, not what the Roadless Rule permits, and the rule already allows fuel reduction. An agency that cannot maintain the roads it has will not become safer by taking on more of them. Public monies need to be spent on fuels reduction, not roads. For the last two summers, I have watched two large fires burn near my house. The Flat Fire in August 2025 burned about 23,000 acres two miles from Sisters, destroyed five homes, and threatened nearly 4,000. The Akawa Butte Fire in July 2026, started by lightning, burned about 27,000 acres northeast of Sisters. What stands between fires like these and my house is defensible space, hardened homes, and fuel treatment near communities, not new roads in remote backcountry. Rescinding protections across roughly 44.6 million acres would not have changed either fire, and it would pull money and attention away from the places where my community is actually at risk. Most importantly, roads bring ignitions. People start the large majority of U.S. wildfires, about 84% in Balch et al. (PNAS, 2017), and ignitions concentrate where people can drive. New roads in currently roadless country would add ignition sources near communities like mine. Fire and smoke are already costing me my livelihood. I run a short-term rental and my income depends on guests who come to Central Oregon for its forests, clean air, and outdoor recreation. In 2026, my bookings fell about30% during fire and smoke events because of smoke and closures. I am not alone. An Oregon State University analysis of Bend lodging data from 2021 to 2025 found that a sustained 10-point rise in August air quality index was associated with about $472,000 in lost lodging revenue, with losses growing as smoke persists. That analysis counted only lodging, not the restaurants, guides, and shops that depend on the same visitors. Because my livelihood rides on how this region handles wildfire, the Forest Service's wildfire case needs to be right. Money and attention spent on new road access in remote backcountry are not spent on the fuel treatment near communities that protects both homes and the local economy. My guests also come for the quiet, undeveloped backcountry the Roadless Rule protects. Roadless watersheds also protect my community's water. Bridge Creek, a tributary of Tumalo Creek, is Bend's main source of drinking water. It flows through the 14,829-acre Tumalo Mountain Roadless Area, which the Roadless Rule currently protects. Forest roads are a documented source of fine sediment to streams. A study of Oregon forest roads found that clearing vegetation from the cutslope and ditch increased sediment production about sevenfold (Luce & Black, Water Resources Research, 1999). Research in Oregon's Cascades found roads were a net source of sediment in the basins studied (Wemple et al., Earth Surface Processes and Landforms, 2001). Sediment degrades spawning habitat, warms streams, and raises treatment costs. New roads upstream of a municipal water supply would add crossings and culverts that will eventually fail, and downstream users and fish would pay for it. Roadless lands protect wildlife. Roads fragment habitat and cut connectivity. For example, esearch at Oregon's Starkey Experimental Forest shows elk select habitat away from roads (Rowland et al., Journal of Wildlife Management, 2000). Central Oregon's migratory and sensitive species depend on intact core areas like Tumalo Mountain. Already, deer populations have dropped nearly 50% in the area where I lived. Rescinding the Roadless Rule will only further threaten this species, too--as well as countless others. Quiet and solitude are a public value. I specifically live in Central Oregon to hunt, hike, and ride in places where it is still quiet. Once a road is built, that character cannot be restored. Already, there are too many roads. I'll end by stating this process is inadequate. A 32-day comment period for a rule affecting tens of millions of acres is far shorter than the periods used when the rule was adopted and in the 2005 rescission attempt, which exceeded 120 days. A decision this large warrants a longer period and public meetings in affected regions, including Central Oregon. I ask that you retain the Roadless Rule in its entirety and direct fire funding to fuel treatment adjacent to communities. Sincerely, Carrie Walker Bend, Oregon