Comment Analysis · Docket FS-2025-0001

FS-2025-0001-603559

Opposes rescissionA3 weakSubstance 6/24Owed an answerPosted 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.
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 Evidence.

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.
Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
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.
Outside the scope The agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.
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
- “concerned about climate change”
- “ignores the carbon implications”
- “mitigate climate impacts”
Wildlife Habitat
- “intact habitat for Oregon Sullivantia”
- “habitat fragmentation reduces biodiversity”
- “ecological dependency”
Water Quality Quantity
- “protect clean air and clean water”
- “disrupts hydrology”
Recreation Tourism Public Use
- “hike in the forests”
- “sense of peace and wholeness”
- “beauty and sanctity of nature”

What it names

National Forests: Mt. Hood National Forest

The comment

Dear Secretary Rollins and Chief Schultz, I am writing to voice my strong opposition to rescission of the Roadless Rule--a very popular and flexible rule that has thus far successfully protected forests, wildlife, the climate, and communities across the country. I am particularly concerned about climate change and follow climate policy as a citizen. This rescission ignores the carbon implications it entails--a grave omission. The Roadless Rule matters to me. It respects the value of intact ecosystems and their role in maintaining health--not just of the forests themselves and the flora and fauna those forests contain--but our own human health. Roadless Rules protect clean air and clean water. They mitigate climate impacts. Geographic locations with roadless areas in place have even been shown to increase local revenue and standard of living. The Roadless Rule reflects human inclusion in the whole of the environment. I live in western Oregon and am always filled with awe when I hike in the forests here. The clean air, the smell of evergreen, and the silence always bring me a sense of peace and wholeness. We disturb these intact forests, through roads and industry, at our own peril. It makes me proud of my country when we decide to protect the beauty and sanctity of nature from unconstrained human development. Regarding the Eagle in the Mt. Hood National Forest, Oregon, near where I live: Without the Roadless Rule, the Eagle IRA in Mt. Hood National Forest loses the protection that currently maintains Pacific Northwest Lowland Mixed Hardwood-Conifer Forest (North Pacific Lowland Mixed Hardwood-Conifer Forest) (GNR, 1.1%, ~178 acres) as intact habitat for Oregon Sullivantia (Sullivantia oregana, G2,). The species is documented present and ecologically associated with this ecosystem through two independent data sources — rescission puts both at risk simultaneously. "70% of remaining forest is within 1 km of the forest's edge, subject to the degrading effects of fragmentation. A synthesis of fragmentation experiments spanning multiple biomes and scales, five continents, and 35 years demonstrates that habitat fragmentation reduces biodiversity by 13 to 75% and impairs key ecosystem functions by decreasing biomass and altering nutrient cycles. Effects are greatest in the smallest and most isolated fragments, and they magnify with the passage of time, with average species loss >20% after 1 year and >50% after 10 years." — PMC / Science Advances, 2015 Oregon Sullivantia (Sullivantia oregana, G2,) does not merely occupy the same space as Pacific Northwest Lowland Mixed Hardwood-Conifer Forest (North Pacific Lowland Mixed Hardwood-Conifer Forest) in Eagle — NatureServe documents an ecological dependency. Road construction that compacts soils, disrupts hydrology, opens canopy gaps, and introduces invasive species into this ecosystem directly undermines the habitat conditions this imperiled species requires for persistence. There are SO many reasons that rolling back the 2001 Roadless Rule is a bad idea. I have only commented on a few here but could have spent hours outlining countless more. I trust other citizens will have touched on these concerns. It strikes me from the research that I have done that the authors of the rescission have not fully addressed the myriad detrimental effects that opening further areas to roadbuilding will create. The Roadless Rule is a popular and successful rule, supported by individuals on both sides of the political spectrum. It is flexible, allowing for roads when they are truly necessary and allowing individual states to modify the guidelines as appropriate. Rescinding this rule, it seems to me, will benefit only the owners of the extractive industries who can take advantage of opened-up wild spaces, to the detriment all others. Even the argument that the rescission will help with fire suppression strikes me as unfounded based on studies showing that wilderness and inventoried roadless Areas have the lowest ignition densities of any land category studied. Please do not rescind this rule. With appreciation, Stacey A. Danner