Comment Analysis · Docket FS-2025-0001

FS-2025-0001-603032

Opposes rescissionA2 moderateSubstance 15/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents that the agency's proposal to rescind the 2001 Roadless Area Conservation Rule contains internal inconsistencies regarding wildfire ignition data (citing DEIS Table 21), small entity economic impacts, and the failure to weigh reliance interests in the cost-benefit analysis, while requesting the selection of the No Action Alternative.

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

Forest Management Wildfire
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “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”
- “quantify the expected increase in human-caused ignitions that would follow from new road access”
- “reconcile the rescission with the ignition data in DEIS Table 21”
Recreation Tourism Public Use
- “walk among century-old trees with my son”
- “Hiking and backpacking into wilderness areas free from the noise of machinery”
- “lost recreation benefit at a minimum of $6.1 million a year”
- “outfitters, guides, and tour operators as affected”
Governance Policy Process
- “The agency must explain, with specificity, why it is departing from its own prior findings”
- “Certifying no significant impact under those conditions is not analysis; it is arithmetic designed to produce a predetermined answer”
- “Soliciting those interests in the Federal Register and then declining to weigh them in the cost-benefit record does not satisfy that obligation”
- “The rule was developed through more than 600 public meetings and 1.6 million comments”
Environmental Protection Biodiversity
- “The America of my dreams is wild, untamed, genuinely free”
- “hear the calls of the hermit thrush and the song of the water ouzel”
- “Protecting these areas is nothing less than safeguarding the very soul of this country”
- “keep strong protections in place by maintaining the 2001 Roadless Area Conservation Rule”

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 knowledgeEA analysisAnalytical gapEvidenceRequestAlternativeLegal

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I ask the Forest Service to honor the long-standing public consensus and keep strong protections in place by maintaining the 2001 Roadless Area Conservation Rule. The America of my dreams is wild, untamed, genuinely free, and the Mt. Hood National Forest is one of the places where that dream lives. Being able to walk among century-old trees with my son, hear the calls of the hermit thrush and the song of the water ouzel next to rapidly flowing waters, is the greatest blessing of my life. My children have learned personal responsibility, self-reliance, and the genuine spirit of the American Dream in the wilderness. Protecting these areas is nothing less than safeguarding the very soul of this country. Three wildfires burned in Mt. Hood National Forest this year. Two of them were caused by human activity, and that activity was enabled by butts in seats travelling on pre-existing roads. That fact is not incidental to this rescission proposal; it is the center of it, because the agency's own record says the same thing. The agency has found that "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." The agency also concedes in its own effects analysis that "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 proposal nevertheless advances rescission partly on wildfire and fuels management grounds. The agency must explain, with specificity, why it is departing from its own prior findings on fire occurrence, and it must reconcile the rescission with the ignition data in DEIS Table 21, which reports fire density on roaded land at a level that dwarfs what occurs inside the roadless areas. Beyond that, I ask that the agency quantify the expected increase in human-caused ignitions that would follow from new road access and weigh that increase honestly against the claimed reduction in wildfire hazard before this proceeding advances any further. The economic analysis supporting this proposal is internally inconsistent in a way the agency has not addressed. The proposal certifies no significant impact on small entities, yet the DEIS names outfitters, guides, and tour operators as affected, and the agency's own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. That certification was reached by spreading an annual expenditure loss of $9 million across every small firm in the sector nationally, rather than examining the outfitters and guides who actually hold permits in the affected areas. The agency concedes that some of those firms may lose those receipts entirely. Certifying no significant impact under those conditions is not analysis; it is arithmetic designed to produce a predetermined answer. The agency should withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas. There is a further procedural problem the agency has created for itself. 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. My family has organized our relationship to the national forests around the protections the 2001 rule provides. Hiking and backpacking into wilderness areas free from the noise of machinery is a year-long activity for us, grounded in the expectation that those areas remain unroaded. The rule was developed through more than 600 public meetings and 1.6 million comments. No comparable process has been offered to undo it. Under the legal standards governing agency reversals, an agency changing course must genuinely assess the reliance interests its prior policy created. Soliciting those interests in the Federal Register and then declining to weigh them in the cost-benefit record does not satisfy that obligation. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one, before any final action is taken. I strongly oppose the proposal to fully or partially rescind the 2001 Roadless Area Conservation Rule, and I urge the US Forest Service to select Alternative 1 (the No Action Alternative) in the Draft Environmental Impact Statement (DEIS). Sincerely, Preston Boyd Gresham, Oregon