Comment Analysis · Docket FS-2025-0001

FS-2025-0001-596111

Opposes rescissionA3 weakSubstance 13/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment documents specific deficiencies in the agency's regulatory flexibility analysis regarding small business impacts in named roadless areas and requests site-specific environmental analysis and an alternative retaining the 2001 Rule's protections.

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 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.
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

Water Quality Quantity
- “decreasing water flow and water clarity”
- “Watersheds fed by roadless areas are part of protecting our nation's water quality”
- “Explain how roads and logging won't have a negative impact on watersheds and water quality”
- “This area is a watershed for drinking water for millions”
Recreation Tourism Public Use
- “I hike and camp in National Forests to enjoy landscapes, bird and wildlife spots, and enjoy solitude”
- “Development would impact the recreation industry and the livelihoods of those who depend on it”
- “negatively impact the tourist and recreation economy”
- “The next generation deserves the right to experience the area as I have: undeveloped and peaceful”
Wildlife Habitat
- “impacting wildlife migrations and homes”
- “Birds and butterflies abounded, and Snake River ran clear through the canyon”
- “Birds would leave based on vehicle noise alone”
- “search for the elusive hellbender”
Governance Policy Process
- “I want an explanation of why this proposal has not included multiple public meetings”
- “I ask that the agency disclose and analyze the site-specific environmental consequences”
- “I ask that the agency respond in the record to each of the issues raised”
- “provide a reasoned explanation for it on the record”

What it names

National Forests: Daniel Boone National Forest Deschutes National Forest Deschutes National Forest Wallowa-Whitman National Forest
Roadless areas: Rogue - Umpqua DivideSnake RiverThree Sisters

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I hike and camp in National Forests to enjoy landscapes, bird and wildlife spots, and enjoy solitude, quietness and dark sky. Public lands must be managed for the current and future public good.That means envisioning the value our public lands have for recreation, wildlife survival, climate change control, water quality, and ensuring there are still undeveloped wilderness areas for future generations. I photograph wildlife, landscapes, and waterfalls and rivers. Road development impacts all of those by changing the scenery, impacting wildlife migrations and homes, and decreasing water flow and water clarity. The kids in my life instinctively notice the difference in a roadless area: the tree canopy, the sound of a waterfall or birdsong not competing with traffic noise. We don’t have the right to deprive future generations of undeveloped national forests. I want an explanation of why this proposal has not included multiple public meetings where the public can make their voices heard in person. Water wars are here. Climate change is fueling water scarcity. Development is fueling water quality issues. Watersheds fed by roadless areas are part of protecting our nation's water quality. Explain how roads and logging won't have a negative impact on watersheds and water quality. Hells Canyon NRA, includes some of Wallowa-Whitman NF, and was on my 2026 photography trip. Birds and butterflies abounded, and Snake River ran clear through the canyon. Proud locals bragged about their forest and generations of family trips to the remote areas. Development would impact the recreation industry and the livelihoods of those who depend on it. Birds would leave based on vehicle noise alone. Deschutes National Forest and a stay in Three Sisters Wilderness area this summer didn’t do it justice. Locals bragged about the lava tubes and waterfalls. Roads would destroy its viewscapes and pristine environment, and negatively impact the tourist and recreation economy. I've explored Daniel Boone NF and the Wolfpen area twice (2022, 2025) to photograph different plants and cliffs and rock formations that change color with morning light, and search for the elusive hellbender. Roads and logging would change that. The next generation deserves the right to experience the area as I have: undeveloped and peaceful. My 2026 visit to the Rogue-Umpqua Divide included hiking to waterfalls deep in the forest. This area is a watershed for drinking water for millions. Developing or building roads through this forest will destroy water quality, impact waterfall viewscapes, and impact the "wow" factor of the area including Crater Lake National Park that has viewscapes of the Rogue-Umpqua Divide. I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule, and specifically about these inventoried roadless areas: - Wallowa-Whitman NF (515,000 acres), Wallowa-Whitman NF, Oregon - Deschutes National Forest (136,000 acres), Deschutes NF, Oregon - Wolfpen (2,835 acres), Daniel Boone NF, Kentucky - Rogue - Umpqua Divide (6,728 acres), Rogue River NF, Oregon - Three Sisters (7,687 acres), Deschutes NF, Oregon I ask that the agency disclose and analyze the site-specific environmental consequences of the proposed rescission for each of these areas, including the effects of the road construction and timber harvest it would newly allow. I raise the following issues for the record and ask that the agency respond to each of them: Issue 1: The small-business certification contradicts the analysis beside it I hike and camp in these areas, and the small outfitters and guides who work this same country help people like me get out there. They deserve a real assessment. The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. The supporting regulatory flexibility analysis reaches its no-impact conclusion by spreading the $9 million annual expenditure loss across every small firm in the sector nationally, rather than assessing the outfitters and guides actually holding permits in the affected areas, and concedes some firms may lose these receipts. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule's protections for the areas named above. Where this proposal rests on factual conclusions that differ from the agency's own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record.