Comment Analysis · Docket FS-2025-0001

FS-2025-0001-593238

Opposes rescissionA1 strongSubstance 14/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment places on the record specific deficiencies in the agency's analysis regarding wildfire ignition data, economic cost-benefit calculations, and legal authority, while asserting the commenter's standing based on direct observation of water quality degradation in the Drift Creek and Cascades areas and recreational use of the Three Sisters and Mt. Jefferson roadless country.

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, 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
- “streams I fish in the Drift Creek area”
- “logging and roadwork actually do to water”
- “favorite spots go turbid, go warm, go empty”
Forest Management Wildfire
- “undercuts the wildfire rationale”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “far higher fire density on roaded land than inside the affected roadless areas”
Recreation Tourism Public Use
- “hike and camp in the Three Sisters area”
- “looking for the quiet and isolation that only unroaded wilderness provides”
- “access to quiet, pristine wilderness”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent”
- “recreation losses of at least $6.1 million a year”
- “$6.9 billion maintenance backlog on existing roads”

What it names

Roadless areas: Drift CreekMt. JeffersonThree Sisters
Law cited: 28 U.S.C. Section 1291

The comment

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

The streams I fish in the Drift Creek area and all along the Cascades have shown me, over a decade, what logging and roadwork actually do to water. I have watched favorite spots go turbid, go warm, go empty. No fish. That experience is what I bring to this comment opposing the rescission of the 2001 Roadless Area Conservation Rule. The agency's own record undercuts the wildfire rationale offered for this proposal. Its text 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 is the agency's, not an outside critic's. I ask that the agency explain why this proposal departs from those prior findings and that it reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. The economics do not pencil out either, and I say that in the plainest sense. The agency's own record 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, the agency's own cost-benefit analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year, with a net present value spanning -$92 million to +$199 million. That range cannot establish a net benefit. At the same time, the agency already carries a $6.9 billion maintenance backlog on existing roads against a road budget of roughly $73 million a year. New roads into country that has none add obligations the agency cannot meet with the resources it already has. The agency must reconcile the proposal with these numbers and explain how expanding a road system already in deficit serves the public interest. I hike and camp in the Three Sisters area and in the Mt. Jefferson roadless country regularly, looking for the quiet and isolation that only unroaded wilderness provides. The last time the agency tried to replace the national rule with a state-by-state approach, the courts found the result wanting. The agency's own record acknowledges "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The agency should address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and explain how this proposal avoids the deficiencies that doomed the last attempt at a state-by-state substitution. Finally, the statutory authority question was resolved by a federal court of appeals. That court stated, exercising jurisdiction pursuant to 28 U.S.C. Section 1291: "we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The Tenth Circuit found the 2001 rule within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and held that it did not create de facto wilderness. If the agency now takes a contrary position, it must say so plainly and explain the legal basis for that departure. Our public lands should be managed for forest health in the broadest sense: streams, habitats, endangered species, trees. Responsible management does not reduce to a single extracted resource. America's lands are as much a part of what makes this country what it is as her people, and anything short of protecting them is a failure toward the children and grandchildren who should inherit them. They deserve access to quiet, pristine wilderness. The agency should say, on the record, how this rescission is consistent with that obligation. Sincerely, Andrew Heaston Corvallis, Oregon