Comment Analysis · Docket FS-2025-0001

FS-2025-0001-608904

Opposes rescissionA1 strongSubstance 17/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents specific deficiencies in the agency's analysis regarding wildfire ignition rates, old-growth exposure, and cost-benefit reconciliation, while citing specific roadless areas in Oregon and requesting quantification of these impacts on the administrative record.

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

Recreation Tourism Public Use
- “I ran a 100 mile race there in September, moving through country where you could go mile after mile without seeing a car or a road”
- “The acreage to run without seeing cars or roads in roadless areas is my favorite way to experience the National Forests”
- “recreation losses of at least $6.1 million a year”
Environmental Protection Biodiversity
- “These places are also where old growth forest still stands, and old growth is where I go to photograph, where biodiversity is greatest”
- “Roadless areas help balance the conservation mission of the Forest Service by protecting some of the 4% of remaining old growth in this country”
- “stands as an echo of the majesty of what the Oregon Coast Range temperate forest used to be”
Water Quality Quantity
- “Intact forests protect and clean water for communities and wildlife”
- “1,522 municipal water intakes sit in watersheds containing affected roadless areas”
- “My tax dollars should go toward protecting those ecosystem services”
Forest Management Wildfire
- “The agency's own analysis undermines the wildfire rationale it offers for this rescission”
- “A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands”
- “quantify the expected increase in human-caused ignitions from new road access”

What it names

National Forests: Gifford Pinchot National Forest Siuslaw National Forest
Roadless areas: Dark DivideDrift CreekHebo 1a
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 placeLocal knowledgeEA analysisAnalytical gapEvidenceRequestLegal

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Dark Divide felt like nothing else I've seen in the Cascades. I ran a 100 mile race there in September, moving through country where you could go mile after mile without seeing a car or a road. That is what roadless areas make possible, and it is what this rescission would end. I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001). I am an ultra trail runner. The acreage to run without seeing cars or roads in roadless areas is my favorite way to experience the National Forests. The Dark Divide, at 52,483 acres in the Gifford Pinchot National Forest, gave me that. So does Drift Creek, 6,333 acres in the Siuslaw National Forest, which sits surrounded by private clearcut logging and stands as an echo of the majesty of what the Oregon Coast Range temperate forest used to be before extractive colonialism stripped it. Hebo 1a, another 13,930 acres in the Siuslaw, is another small remnant of what remains of that rainforest. These places are also where old growth forest still stands, and old growth is where I go to photograph, where biodiversity is greatest, and where, even as summers grow hotter and drier, the forest still feels cool and damp. What remains of that old growth is rare. Roadless areas help balance the conservation mission of the Forest Service by protecting some of the 4% of remaining old growth in this country. Oregon holds 211 inventoried roadless areas totaling 1,937,741 acres. The agency should say plainly, on the record, what share of remaining old growth in Oregon would be exposed to road construction and timber extraction if those areas lose their protection. The agency's own analysis undermines the wildfire rationale it offers for this rescission. The record states: "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." 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. I ask that the agency quantify the expected increase in human-caused ignitions from new road access and weigh it against the claimed reduction in wildfire hazard, and that it explain how the proposal departs from its own prior findings as recorded in DEIS Table 21. Intact forests protect and clean water for communities and wildlife. Across the Pacific Northwest region, which includes Oregon, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. My tax dollars should go toward protecting those ecosystem services, not toward building new roads into country that has none, especially when the agency already carries a $6.9 billion maintenance backlog against a road budget of roughly $73 million a year. The record the agency itself assembled states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency must reconcile the proposal with its own cost-benefit analysis, which projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. How does an action whose own analysis cannot establish a net benefit justify expanding a road system the agency cannot afford to maintain? The rule as written already accommodates the concerns the agency invokes. It "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." I ask that the agency identify specifically which burdens are not already addressed by those existing exceptions, including those for public health and safety, existing mineral leases, and community wildfire protection, and that it quantify each claimed burden with evidence in the record. I commented on this rescission in 2025. By the agency's own count, 99.5% of comments were against it. That the administration proceeds regardless raises a direct question about its obligations under the Administrative Procedure Act and the notice-and-comment process. The agency must address in the record how a response rate of that character is consistent with its duty to consider public input rather than to discard it. Sincerely, Brian Dugovich Corvallis, Oregon