Comment Analysis · Docket FS-2025-0001

FS-2025-0001-612808

Opposes rescissionA3 weakSubstance 10/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents that the agency's proposal to rescind the Roadless Area Conservation Rule conflicts with its own prior findings regarding wildfire ignition rates, water quality impacts on municipal supplies, and economic cost-benefit analyses, while also highlighting a procedural deficiency in the lack of public meetings for the rescission.

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 Analytical gap.

Standard dismissals it defeats

Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
Outside the scope The agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.

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.
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.
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

Water Quality Quantity
- “water quality is crucial to all life”
- “1,522 municipal water intakes sit in watersheds containing affected roadless areas”
- “Bridge Creek... supplies roughly 60 percent of Bend's municipal drinking water”
- “More roads will impact the watersheds that communities depend on”
Forest Management Wildfire
- “Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “All research shows more roads in forests increase risk, not reduce it”
- “reconcile the rescission with the ignition data in its own draft environmental impact statement”
Wildlife Habitat
- “bird richness declines with road presence in forested habitat”
- “road-noise experiments in a roadless area cut bird abundance by over a quarter”
- “elk survival rates rose during a road closure and fell again when the gates were removed”
- “We continue to lose wild areas, wildlife species”
Governance Policy Process
- “The procedural record here is indefensible”
- “The Forest Service held more than 600 public meetings... It has held none to undo it”
- “The public has consistently spoken up for public lands”
- “The government needs to listen to the people and not yield to short-term corporate profit”

What it names

Roadless areas: Bend WatershedDrift CreekMiddle SantiamOpal CreekThree Sisters

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 The Willamette, Siuslaw, and Deschutes national forests have shaped three generations of my family. I have been going to Opal Creek since the 1980s, and it is a special place to Oregonians. My family was heartbroken when wildfire destroyed much of that landscape, and I have volunteered many hours helping restore access and trails there. From summiting my first mountain to my son doing the same in the Three Sisters area, these forests have been a constant. I hike, camp, and do volunteer trail work across these forests because I believe in stewarding the land for current and future generations. Proposed mining at Opal Creek would heavily impact forest recovery and water quality for the entire watershed, and I am filing this comment to oppose the rescission of the 2001 Roadless Area Conservation Rule under Docket FS-2025-0001. The roadless areas I know include Opal Creek and Middle Santiam in the Willamette, Drift Creek and the Siuslaw, and the Three Sisters, West South Bachelor, and Bend Watershed areas in the Deschutes. Oregon holds 211 inventoried roadless areas totaling 1,937,741 acres. The birds I want to hear singing without the roar of traffic live in these places. The agency's own record states that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. The agency's own citation found elk survival rates rose during a road closure and fell again when the gates were removed. The proposal justifies rescission in part on wildfire grounds, but 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." I live near a national forest in Oregon. We have had our worst wildfire year ever, with lives lost and resources damaged. All research shows more roads in forests increase risk, not reduce it. We cannot afford to increase that risk. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence and 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. Water quality is crucial to all life, and roadless areas are the keystone to that resource. Across the Pacific Northwest region, which includes Oregon, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. Bridge Creek, running through old-growth forest on the Deschutes, supplies roughly 60 percent of Bend's municipal drinking water. Roadless areas are critical to Bend's economy both recreationally and as a clean water source for the community. More roads will impact the watersheds that communities depend on. The agency must explain how it has weighed water quality and municipal supply risk for the communities downstream of these areas. The economics do not hold together. 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." Mountain biking is a new sport for our family, and roadless areas create a safe and peaceful opportunity that depends on these places staying unroaded. The agency should reconcile its proposal with its own economic 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 explain how an action whose own Cost Benefit Analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog. Our public lands need to be managed for the long-term benefit of people, the planet, and wildlife. The primary purpose is not resource extraction and corporate profit. Finally, the procedural record here is indefensible. The Forest Service held more than 600 public meetings and took 1.6 million comments to write the original rule. It has held none to undo it. The public has consistently spoken up for public lands and for keeping roadless areas. The government needs to listen to the people and not yield to short-term corporate profit. My family's decades of use, volunteerism, and investment in these forests are exactly the reliance the agency invited and then ignored. We continue to lose wild areas, wildlife species, carbon-storing old-growth, and protected watersheds. Once many of these things are lost, they will be gone forever. Sincerely, Nelson Kline Salem, OR