Opposes rescissionA0 noneSubstance 6/24Posted October 7, 2026 On Regulations.gov
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.
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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
A0 none: Counted, not answered.
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Misreads the proposalThe agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
Not requiredThe agency says the analysis the comment asks for is not required. Cannot be defeated from the comment text alone.
Preference notedThe 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 shownThe agency says the comment asserts a harm without showing how the action causes it. Defeated when the comment shows the mechanism.
Outside the scopeThe agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.
Certified not substantiveThe agency certifies the comment raises nothing substantive. Defeated when the comment alleges illegality, which is substantive by the definition the certification runs on.
“Roadless areas provide intact habitats for hundreds of threatened and endangered species”
“It is far better - and more cost effective - to keep habitats intact than to attempt to restore damaged habitats”
“Many other wildlife species are dependent on intact habitats that are not broken up by roads”
“Some of our best old growth stands are in roadless areas, places that are critical for species dependent on the conditions only an old growth forest provides”
“About 85% of fires are human caused and they are about 4x more likely to start in close proximity to roads”
“Roads increase fire danger, roadless areas decrease the risk”
“Logged forests also increase fire risk & intensity as the ground warms up the vegetation becomes stressed & dries out”
“That cool shade which aids in moisture retention is also important for the resilience of forests to fires”
The comment
I am writing to express my opposition to rescinding the Roadless Area rule of 2001. I prefer alternative 1 in the DEIS. I live in close proximity to both the Mt Hood and Gifford Pinchot National Forests and visit both forests regularly to hike; my drinking water comes from The Dalles watershed on the Mt Hood NF. I also visit other national forests around the west to recreate and also to assist with rare plant monitoring - I am a retired botanist.
Roadless areas provide intact habitats for hundreds of threatened and endangered species, both plant and animal. It is far better - and more cost effective - to keep habitats intact than to attempt to restore damaged habitats as part of recovery efforts to improve conditions for T&E species. I have been involved in restoration work and it is slow, expensive, and not always successful. T&E species are important parts of functional ecosystems, even if we don’t understand how they fit in, and by law (the ESA) and what is actually in our own best interests and morally right, they need to be protected and prevented from going extinct. Many other wildlife species are dependent on intact habitats that are not broken up by roads or visited by humans.
Road construction is the largest source of water degradation and road failures on national forest lands are all too common. The FS already has twice the road mileage of our national highway system but is billions of dollars behind in road maintenance. This is incredibly obvious when driving around - roads that are the main arteries into the forest are seriously neglected with potholes, road slumps, and unbrushed shoulders blocking the view of oncoming vehicles or obstacles. Some have washouts or missing bridges. And these are the primary roads - taking the secondary roads is even worse, if they are even passable. Why would anyone want to add still more roads when they can’t begin to maintain what they have? Ever since the agency decided to contract out road maintenance rather than doing it themselves the roads have steadily deteriorated and become unsafe. When logs fall across roads it looks like users cut them out enough to get past instead of the FS clearing the road of the hazard.
Drinking water for 1 million Oregonians, including me, comes from the Mt Hood NF and nationwide forest service land provides water for over 25 million Americans. Roads & logging within these watersheds are incompatible, leading to heavy sedimentation instead of clean filtered water. Large openings from logging and road corridors lead to quicker snowmelt and runoff, lessening the shade and sponge effect of an intact forest which helps retain water for a slow release through summer months. That cool shade which aids in moisture retention is also important for the resilience of forests to fires. About 85% of fires are human caused and they are about 4x more likely to start in close proximity to roads. Roads increase fire danger, roadless areas decrease the risk. Logged forests also increase fire risk & intensity as the ground warms up the vegetation becomes stressed & dries out.
Roads are corridors for invasive species, particularly weeds which damage habitat.
Recreation has become a primary use on national forests and is an important and fairly reliable source of income for surrounding communities, steadier than the boom & bust pattern of logging which employs fewer people since what logging and milling do occur is more automated. I’ve seen that an estimated $9 million would be lost annually from recreation spending in communities near roadless areas. Many roadless areas are popular for the lakes, waterfalls, scenic views and other features that they contain and that would be damaged with roading & resource extraction. I hike & visit many roadless areas and recognize that they remained roadless because of their topography and often poor quality trees (for harvest) due to inhospitable growing conditions. Some of our best old growth stands are in roadless areas, places that are critical for species dependent on the conditions only an old growth forest provides. National forests are managed for multiple uses and retaining roadless areas ensures many of those uses are protected.
In closing I reiterate that I am opposed to rescinding the Roadless Rule which has been so effective for the last quarter century and which from the beginning has been overwhelmingly popular with Americans. These are our public lands and we don’t want them damaged by roads and development any more than they already have been. There is plenty of forest that has more roads than can be maintained on current inadequate budgets and areas that were previously logged that can be re-entered for a second harvest. Keep the Roadless Rule intact.