Comment Analysis · Docket FS-2025-0001

FS-2025-0001-610110

Opposes rescissionA1 strongSubstance 16/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment establishes that the agency's proposed rescission of the Roadless Area Conservation Rule is contradicted by its own record regarding wildfire ignition risks, economic costs, and regulatory flexibility analysis, and requests specific reconciliations and withdrawals of certifications 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

Forest Management Wildfire
- “wildfire rationale the agency offers for rescission is flatly contradicted”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “Forests and spaces protected in the Roadless Rule are managed forests”
- “minimal but responsible logging to mitigate wildfire risk”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue”
- “recreation losses of at least $6.1 million a year”
- “agency already carries a $6.9 billion maintenance backlog on its existing road system”
Legal Regulatory Framework
- “regulatory flexibility analysis underlying this proposal does not hold together”
- “certifies no significant impact on small entities while the DEIS names outfitters, guides, and tour operators as affected”
- “Exceptions for public health and safety, existing mineral leases, and community wildfire protection are already embedded in the rule”
- “agency should withdraw the certification and conduct the analysis on the entities actually operating”
Environmental Protection Biodiversity
- “colors, landscapes, trees, climate, and wildlife of this region are unlike anything that can be reconstructed once lost”
- “detrimental to the health and safety of all-environment, wildlife, and recreational participants”
- “steward our resources toward maintaining what we have”
- “spending money on destructive infrastructure that exacerbates environmental and wildlife health”

What it names

National Forests: Siuslaw 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 placeLocal knowledgeEA analysisAnalytical gapEvidenceRequest

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 My name is Olivia Clements and I am a lifelong Pacific Northwesterner. As an artist, photography taught me to look closely, and what I keep finding along the Pacific Coast is irreplaceable. From the Mt. Baker-Snoqualmie National Forest to the Siuslaw National Forest to the Humboldt Redwoods, the colors, landscapes, trees, climate, and wildlife of this region are unlike anything that can be reconstructed once lost. I oppose the rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001, because the agency's own record does not support it. As it currently stands, the argument to repeal the Roadless Rule is based on faulty logic and false claims. The wildfire rationale the agency offers for rescission is flatly contradicted by its prior findings. The agency's own 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." The Siuslaw and the forests I travel to photograph already face pressure. Adding roads does not reduce ignition risk; the agency's own data says the opposite. I ask the agency to explain why this proposal departs from those prior findings and to reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. Additionally, arguments for the repeal of the Roadless Rule strongly imply that roadless forests as they currently stand are unmanaged. This could not be further from the truth. Forests and spaces protected in the Roadless Rule are managed forests, meaning they undergo steps to reduce fire risk-including minimal but responsible logging to mitigate wildfire risk. To imply that a roaded forest is a safer forest is not only false, but detrimental to the health and safety of all-environment, wildlife, and recreational participants. The fiscal reasoning is no stronger. The agency's own record 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." These are not numbers that describe a national economic emergency. The agency's own Cost Benefit Analysis 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. Meanwhile, the agency already carries a $6.9 billion maintenance backlog on its existing road system. My own view is simple: steward our resources toward maintaining what we have, rather than spending money on destructive infrastructure that exacerbates environmental and wildlife health. You can lay cement anywhere, but you can't replace our one, precious earth. The agency must explain on the record how an action whose own analysis cannot establish a net benefit justifies expanding a road system already in deficit. The agency also claims permitting burdens as a reason for rescission, but the rule as written already contemplates the situations it cites. The rule, by the agency's own description, "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)." Exceptions for public health and safety, existing mineral leases, and community wildfire protection are already embedded in the rule. The agency should identify, specifically and quantitatively, which burdens are not already addressed by those exceptions, and place that accounting on the record. Finally, the regulatory flexibility analysis underlying this proposal does not hold together. The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides, and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. That certification is reached by averaging an estimated loss across every small firm in the sector nationally, rather than examining the outfitters and guides who actually hold permits in the affected areas. The photographers, guides, and small operators who work in forests like the Siuslaw are not a national average; they are specific businesses facing specific losses. The agency should withdraw the certification and conduct the analysis on the entities actually operating in the potentially affected roadless areas. Sincerely, Olivia Clements Seattle, WA