Comment Analysis · Docket FS-2025-0001

FS-2025-0001-287233

Opposes rescissionA0 noneSubstance 7/24Posted August 31, 2026 On Regulations.gov

In short: The comment establishes that specific roadless areas in the Uinta-Wasatch-Cache and Manti-La Sal National Forests, including White Pine, Mineral Fork, Dog Lake, Elbow Fork, and the Kokopelli trail, are critical for backcountry recreation and municipal water supply, and that the 2024 Yellow Lake Fire was caused by commercial logging rather than a lack of road access.

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 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.
  • Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
  • 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.
  • 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.

Topics

  • Recreation Tourism Public Use
    • “backcountry ski all winter”
    • “undeveloped character is exactly what makes them worth skiing”
    • “no roads, minimal crowding”
    • “permanently change the experience that draws people to them”
  • Water Quality Quantity
    • “municipal watersheds that supply drinking water”
    • “Roads are one of the largest sources of sediment and erosion”
    • “protect the water quality that hundreds of thousands of people downstream rely on”
  • Forest Management Wildfire
    • “human-caused ignitions are concentrated near roads”
    • “ignited by a commercial logging operation, not by a lack of road access”
    • “targeted fuels treatment and prescribed fire”
    • “already allowed under the existing rule”

What it names

Roadless areas
Little CottonwoodWhite Pine

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Legal

I am writing as a Salt Lake City resident to oppose the proposed rescission of the 2001 Roadless Rule. I live in the Avenues, at the base of the Wasatch, and roadless national forest land is not an abstraction to me. It is where I backcountry ski all winter, where I hike, and where I bikepack. I am asking the Forest Service to withdraw this proposal and keep the Roadless Rule's protections in place, including on the Uinta-Wasatch-Cache and Manti-La Sal National Forests here in Utah. Recreation: The roadless canyons above Salt Lake City, including areas like White Pine, Mineral Fork, Dog Lake, and Elbow Fork, are the backbone of the region's backcountry skiing. Their undeveloped character is exactly what makes them worth skiing: no roads, minimal crowding, and terrain that has not been fragmented by logging infrastructure. Farther south, the Manti-La Sal National Forest and trails like the Kokopelli, which I have bikepacked, depend on the same undeveloped backcountry character. Opening these areas to road construction would permanently change the experience that draws people to them in the first place. Water quality: Big and Little Cottonwood Canyons are municipal watersheds that supply drinking water to the Salt Lake Valley. Roads are one of the largest sources of sediment and erosion into forest streams. Keeping these upper watersheds roadless is a direct, low-cost way to protect the water quality that hundreds of thousands of people downstream rely on. Wildfire: I understand the proposal is framed around reducing wildfire risk, but the evidence points the other way. The large majority of wildland fires nationally are human-caused, and human-caused ignitions are concentrated near roads and access points, not in remote roadless terrain. Utah's own 2024 Yellow Lake Fire in the Uinta Mountains, which burned over 33,000 acres, was ignited by a commercial logging operation, not by a lack of road access. More roads mean more vehicle traffic, more equipment, and more opportunities for human-caused ignition in places that currently see very little of it. If the goal is genuinely to reduce wildfire risk, the answer is targeted fuels treatment and prescribed fire, both of which are already allowed under the existing rule, not a blanket rollback of roadless protections. For these reasons, I urge the Forest Service to withdraw the proposed rescission and retain the 2001 Roadless Rule in its entirety, including for Utah's national forests. Thank you for considering my comment. Ally Johnson Salt Lake City, Utah

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