Comment Analysis · Docket FS-2025-0001

FS-2025-0001-606112

Opposes rescissionA1 strongSubstance 13/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment establishes that the agency's DEIS contains internal contradictions regarding fire risk and economic net benefits, fails to apply cited biodiversity loss percentages to the affected acreage, and does not identify specific operational burdens outside existing regulatory exceptions, thereby documenting deficiencies in the record supporting the rescission of the Roadless Area Conservation Rule.

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

A1 strong: Must be answered — it names the law.

Owed an answer on Analytical gap, Evidence, Legal.

Standard dismissals it defeats

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.
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.
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.

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.
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.

Topics

Wildlife Habitat
- “largest roadless complex outside designated wilderness”
- “longest salmon migration in North America”
- “habitat fragmentation reduces biodiversity”
- “Species that depend on these corridors... need intact buffers”
Water Quality Quantity
- “removing riparian vegetation can raise stream temperatures”
- “cold-water species tolerate”
- “Essential Fish Habitat managed by NMFS”
- “Salmon supports the longest salmon migration”
Recreation Tourism Public Use
- “witness - and enjoy - the true majesty of unexploited nature”
- “forests I have traveled, paddled, and camped in since childhood”
- “recreation losses of at least $6.1 million a year”
- “backcountry will not recover... meaningful to the backpackers, anglers, hunters, and skiers”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent”
- “net present value spanning -$92 million to +$199 million”
- “Forest Service road system already carries a $6.9 billion maintenance backlog”
- “contribute more to the regional economy than logging ever could”

What it names

National Forests: Olympic National Forest Salmon-Challis National Forest Wallowa-Whitman National Forest
Law cited: 36 C.F.R. Section 294.12

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeEA analysisAnalytical gapEvidenceRequestAlternativeLegal

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Roadless areas are some of the few places where we can witness - and enjoy - the true majesty of unexploited nature. I oppose rescission of the 2001 Roadless Area Conservation Rule because the agency's own record does not support the action, and because the forests I have traveled, paddled, and camped in since childhood will bear the consequences. Wildfire. The DEIS states: "A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." If roads increase ignition, the agency must explain why expanding the road network into 40.1 million acres of protected land advances fire management rather than undermining it, and reconcile the rescission with DEIS Table 21, which reports far higher fire density on roaded land. Economics. The DEIS acknowledges that "the total timber volume affected by this rule is less than 0.5 percent of total United States production." Its analysis projects timber revenue of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year, with a net present value spanning -$92 million to +$199 million, while the Forest Service road system already carries a $6.9 billion maintenance backlog. The agency should explain how an action whose own analysis cannot establish a net benefit justifies expanding a road system in that condition. Fish and wildlife. I have rafted the Main and Middle Forks of the Salmon River through the Salmon-Challis National Forest, home to the largest roadless complex outside designated wilderness in the lower 48: 58 inventoried areas totaling 2,264,064 acres. The Salmon supports the longest salmon migration in North America, over 900 miles. The DEIS acknowledges that removing riparian vegetation can raise stream temperatures beyond what cold-water species tolerate, and that the affected area includes Essential Fish Habitat managed by NMFS. It also cites findings that habitat fragmentation reduces biodiversity by 13 to 75 percent, yet never applies that range to the 40.1 million affected acres. The agency should do so before proceeding. Existing exceptions. The rule already accommodates the burdens the agency cites: it "generally banned road building subject to limited exceptions," including reserved or outstanding rights and construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3). The agency has not identified which operational burdens fall outside these exceptions. It should identify and quantify them on the record rather than treating administrative complexity as grounds to eliminate protections that have stood for over two decades. Born and raised in Idaho, I have camped, hiked, backcountry skied, and backpacked in Oregon's Wallowa-Whitman National Forest since childhood. If its 515,000 roadless acres are opened to roads and logging, that backcountry will not recover in any timeframe meaningful to the backpackers, anglers, hunters, and skiers who contribute more to the regional economy than logging ever could. Species that depend on these corridors, including Chinook salmon, steelhead, bull trout, wolverine, mountain goat, bighorn sheep, and gray wolf, need intact buffers around protected roadless areas. Our public lands should be managed for all citizens, not sold off to the highest bidder, and preserved for future generations, from the Salmon-Challis to the Wallowa-Whitman to the Olympic National Forest, already hemmed by clear-cuts visible from Hurricane Ridge. I urge the agency to withdraw the proposed rescission. Sincerely, Tracy Andrews Portland, Oregon