Comment Analysis · Docket FS-2025-0001

FS-2025-0001-600652

Opposes rescissionA2 moderateSubstance 16/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment establishes that the agency's analysis fails to account for the maintenance backlog of existing roads, the specific economic impacts on local small entities versus national averages, the unweighed reliance interests of the public, the increased wildfire ignition density from new road access, and the foreseeable downstream effects of land management plan amendments, thereby documenting significant deficiencies in the environmental and economic review of the proposed rescission.

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

Water Quality Quantity
- “Roadless watersheds feed the water supply”
- “roads and their associated facilities can produce the large majority of sediment”
- “sediment risk from new road construction in these watersheds”
Forest Management Wildfire
- “Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas”
- “human-caused ignitions increase in abundance with proximity to roads”
- “road access could increase the number and frequency of wildfires”
Recreation Tourism Public Use
- “Mountain biking and camping with my family”
- “I ride the Forest Road 44 trails”
- “lost recreation benefit at a minimum of $6.1 million a year”
Legal Regulatory Framework
- “regulatory flexibility certification in this proposal does not hold up”
- “Soliciting those interests and then leaving them unweighed in the economic analysis is not a lawful change of course”
- “Rescinding the rule without analyzing what plan amendments will follow is analyzing only half the action”

What it names

National Forests: Mt. Hood National Forest

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Mountain biking and camping with my family in the Mt. Hood National Forest is not an abstract interest. I ride the Forest Road 44 trails. My kids come with me. That is the ground this comment stands on, and it is the ground this proposal puts at risk. The agency's own data on road infrastructure should stop this proposal before it starts. The Forest Service is already billions of dollars behind on maintaining the roads it has. Building new roads into country that currently has none compounds a maintenance burden the agency has not come close to meeting. The sensible course is to focus resources on improving current infrastructure, not extending it into areas that are still intact. I ask that the agency explain on the record why adding new road miles is justified when the backlog on existing roads remains unaddressed. Roadless watersheds feed the water supply for an enormous number of Americans, and the Forest Service's own analysis acknowledges that roads and their associated facilities can produce the large majority of sediment from a timber operation. Clean water is the best legacy we can leave the next generation. I want my kids to inherit that, and I want the agency to answer directly whether the sediment risk from new road construction in these watersheds has been weighed against whatever timber or resource benefit is claimed. The regulatory flexibility certification in this proposal does not hold up against what the supporting documents actually say. "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 certification reaches its conclusion by distributing the projected expenditure loss across every small firm in the sector nationally, rather than looking at the outfitters and guides who actually hold permits in the affected areas. That is not an assessment; it is an average used to obscure a real impact. 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. The proposal also invites public comment on reliance interests and then does nothing with them. "The proposal solicits 'any reliance interests in the current rule that could be affected by this proposal' (91 FR 53830-31), and the Cost Benefit Analysis weighs none." Families who have organized their recreation around roadless protections, outfitters who have built permit-dependent businesses under the existing rule, and communities whose water comes from these watersheds have all relied on the 2001 rule across more than two decades. Soliciting those interests and then leaving them unweighed in the economic analysis is not a lawful change of course. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one. On fire, the agency's own numbers argue against the proposal. "Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads." The effects analysis itself concedes that road access could increase the number and frequency of wildfires. Opening these areas to road construction would move the ignition density inside them toward the much higher rate observed on roaded land. The agency must quantify the expected increase in human-caused ignitions from new road access and weigh it against the claimed reduction in wildfire hazard before this proposal can proceed. Finally, the proposal treats the most consequential downstream effects as outside its scope while simultaneously asking the public to comment on them. "The proposed rule concedes that subsequent land management plan amendments and revisions 'could increase the area where timber harvest and road construction would be allowed,' declares changes to plans beyond the scope of the proposal, and then requests public comment on them (91 FR 53830)." Rescinding the rule without analyzing what plan amendments will follow is analyzing only half the action. The foreseeable plan-amendment scenario, including expanded timber harvest area, belongs inside this analysis, not deferred to a later process the public cannot yet reach. The Forest Road 44 trails, the watershed those forests feed, and the country I want my children to know the way I know it are what is actually at stake. The 2001 rule should stand. Sincerely, Emily Martin Hood River, Oregon