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.
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
A0 none: Counted, not answered.
Still open to the agency
Alternative already eliminatedThe agency says it considered and eliminated the alternative the comment proposes, with a reason. Cannot be defeated from the comment text alone.
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Deferred to a later decisionThe agency says the point belongs to a later, site-specific decision. Cannot be defeated from the comment text alone.
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.
To the USDA Forest Service:
I strongly oppose the proposal to eliminate, weaken, or alter the Roadless Rule. As a resident of the Portland, Oregon area, I depend on the forests of Mt. Hood National Forest and the Bull Run watershed, and I urge the agency to select Alternative 1, the No Action alternative, and keep current roadless protections in place.
Some changes can't be undone. Once roads and clearcuts fragment a roadless forest, the damage is permanent. These are some of the most intact, resilient ecosystems left in our country. They filter and store clean water, shelter vulnerable species, and serve as critical carbon sinks. A decision that can't be reversed deserves the highest bar of justification, and this proposal doesn't meet it.
This is about the health of my neighbors. In the Portland area, our drinking water comes from the Bull Run watershed in Mt. Hood National Forest, which serves roughly a million people in my region. Protecting the forests that surround and feed our water supply is a public health issue. Road building and logging in these landscapes put at risk water that my family, my neighbors, and our community drink every day. Roads also bring more fire: research shows wildfires are four times more likely to ignite near roads. Fighting fires in remote areas is dangerous and costly, and it pulls resources away from protecting communities. The Roadless Rule already includes exceptions for emergencies such as wildfire, so rescinding it for this stated purpose is unnecessary and dangerous.
The economics don't add up. New logging roads in remote backcountry are extraordinarily expensive and leave taxpayers with billions of dollars in long-term maintenance costs for roads that are rarely used. Meanwhile, logging roadless forests degrades services our economy already depends on. Mt. Hood National Forest draws visitors from across the Portland metro area and beyond, supporting a multi-billion-dollar outdoor recreation industry nationwide, along with sacred sites, traditional foods, wildlife habitat, and carbon storage. Trading these for short-term logging profits is a net loss for communities and future generations.
Americans have already made this decision. The original Roadless Rule came out of the most extensive public engagement process in the history of federal rulemaking, and over 95% of commenters supported strong protections. Last fall, over 600,000 people commented on the Notice of Intent, and over 99% opposed rescinding the rule. Now the agency is pursuing a rushed, abridged process that limits and ignores input from citizens, scientists, Tribes, and local communities. Overriding a clear, repeatedly expressed public mandate is undemocratic, and it is irresponsible for a decision of this consequence.
For more than two decades, the Roadless Rule has balanced ecological, economic, and cultural values. Both Alternatives 2 and 3 would have severe consequences for wildlife, biodiversity, clean water, climate resilience, cultural resources, local economies, and outdoor recreation. I urge the USDA to abandon this effort, select Alternative 1, and maintain full Roadless Rule protections for the forests that protect my community's water and the wild places we all share.
Sincerely,
Timothy Wittig
OR