Comment Analysis · Docket FS-2025-0001

FS-2025-0001-598784

Opposes rescissionA2 moderateSubstance 14/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment documents that the draft EIS fails to quantify greenhouse gas emissions, water treatment costs, and lifecycle road costs, while citing specific data on wildfire ignition rates, water intakes, and economic impacts to support the retention of the Roadless Area Conservation Rule in Eugene, Oregon.

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

A2 moderate: Hard to dismiss — it shows cause and effect.

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.
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.

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.
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

Climate Carbon Storage
- “old-growth stands that hold carbon for centuries”
- “Logging releases stored carbon, and replacement stands take decades to recover it”
- “Roadless areas are one of the few climate solutions we already own”
- “quantify the greenhouse gas emissions and lost sequestration”
Water Quality Quantity
- “protecting the rivers that supply our drinking water”
- “roadless areas typically have good water quality due to limited disturbance”
- “road construction and native-surface roads are the largest source of sediment”
- “more than 7,000 municipal water intakes within inventoried roadless areas”
Wildlife Habitat
- “sustain our salmon”
- “adversely affect 327 listed species and 71 critical habitats”
- “including Oregon's Chinook, coho, and steelhead”
- “effect on salmon recovery”
Forest Management Wildfire
- “higher road density increases human-caused wildfire ignitions”
- “fires are about four times more likely to start near a road”
- “The Rule already allows roads and cutting for emergencies, restoration, and wildfire risk reduction”
- “rescission is not needed for fire safety”

What it names

Roadless areas: Hardesty Mountain

The comment

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

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I support Alternative 1, the No Action alternative. I am 34 years old, I live in Eugene, Oregon, and I work at a local watershed council protecting the rivers that supply our drinking water and sustain our salmon. I plan to raise a family here, and this decision will shape the Oregon my children inherit. I want them to drink clean water from our rivers, to hike and fish in places like Hardesty Mountain, and to grow up among old trees that are still standing and still pulling carbon out of the air. Roadless areas are one of the few climate solutions we already own, and they cost nothing to keep. I am asking the Forest Service not to trade away my generation's future for short-term timber volume. I submit this comment as an individual, and the views are my own. Roadless areas protect some of the largest intact forests in the National Forest System, including old-growth stands that hold carbon for centuries and keep sequestering as they age. Alternatives 2 and 3 would allow new roads and commercial logging across up to 18.2 million acres in the short term. Logging releases stored carbon, and replacement stands take decades to recover it, which is time the climate does not give us. The draft EIS also acknowledges that higher road density increases human-caused wildfire ignitions, and research finds fires are about four times more likely to start near a road than in roadless forest. More ignitions mean more emissions and more stored carbon lost. The Rule already allows roads and cutting for emergencies, restoration, and wildfire risk reduction, so rescission is not needed for fire safety. The final EIS should quantify the greenhouse gas emissions and lost sequestration from road construction, harvest, and added ignitions, apply the social cost of carbon, and explain how rescission is consistent with climate goals through 2050. As snowpack declines and summers dry, intact forest watersheds matter more. The draft EIS acknowledges that roadless areas "typically have good water quality due to limited disturbance," and that road construction and native-surface roads are the largest source of sediment from timber harvest. Forest Service data show more than 7,000 municipal water intakes within inventoried roadless areas, and Oregon communities including Eugene draw from watersheds that include them. The agency's own analysis finds Alternative 2 would "adversely affect" 327 listed species and 71 critical habitats, including Oregon's Chinook, coho, and steelhead. The final EIS should quantify the added treatment costs for downstream utilities and ratepayers and the effect on salmon recovery. The agency already reports a $6.9 billion road maintenance backlog, yet Alternative 2 would open 18.2 million acres to new roads. Meanwhile, visitors to the affected forests spent $8.5 billion in local communities in 2024, and the agency itself estimates Alternative 2 would reduce visitor spending by about $9 million per year. The final EIS should compare lifecycle road costs with expected timber receipts. The draft EIS reports that most consulted Tribal governments oppose rescission and concedes long-term negative effects on Tribal rights and interests. Alternative 3 is no compromise: it would remove protections from about 1.4 million acres, 75% of Oregon's roadless areas, including Hardesty Mountain near Eugene, and would degrade the intact forest left beside every stripped acre. About 95% of 1.6 million comments supported the Rule when it was adopted, and over 99% of more than 600,000 comments in 2025 urged retaining it. A 300-page draft EIS also cannot be meaningfully reviewed in this short a comment period. For these reasons, I urge the Forest Service to select Alternative 1 and retain the Roadless Rule in full. Alex Renirie, Eugene, OR