Comment Analysis · Docket FS-2025-0001

FS-2025-0001-305095

Opposes rescissionA1 strongSubstance 14/24Owed an answerPosted September 2, 2026 On Regulations.gov

In short: The comment establishes that the DEIS fails to adequately analyze the necessity of full rescission, the impact on drinking water quality for Salt Lake City, and the lack of a Utah-specific alternative that balances fire risk reduction with road prohibitions, thereby rendering the range of alternatives inadequate under NEPA.

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, Alternative, 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

  • Water Quality Quantity
    • “80 percent of Salt Lake City's watershed sits within this forest”
    • “Forest roads are a leading source of sediment in forested watersheds”
    • “risk to the drinking water of over a million people”
  • Governance Policy Process
    • “range of alternatives inadequate under NEPA”
    • “DEIS does not explain why that is necessary”
    • “request that a Utah-specific alternative... be analyzed in the final EIS”
  • Forest Management Wildfire
    • “2001 rule already allows cutting and removal of small-diameter trees to reduce the risk of uncharacteristic wildfire”
    • “amend them [the exceptions]”
    • “planned, funded fuels treatment on this forest have actually been blocked by the rule”
  • Recreation Tourism Public Use
    • “backcountry ski and trail run in the inventoried roadless areas”
    • “White Pine, Mineral Fork, and the Millcreek drainages”

What it names

National Forests
Wasatch-Cache National Forest
Roadless areas
White Pine
Law cited
36 CFR 294.13

The comment

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

I live in Cottonwood Heights, Utah, and I backcountry ski and trail run in the inventoried roadless areas of the central Wasatch, including White Pine, Mineral Fork, and the Millcreek drainages on the Uinta-Wasatch-Cache National Forest. I oppose the rescission and ask the Department to select the no-action alternative. The stated purpose is wildfire risk reduction, but the 2001 rule already allows cutting and removal of small-diameter trees to reduce the risk of uncharacteristic wildfire, and it has never restricted fire suppression. If those exceptions are too narrow in practice, amend them. Full rescission also strips protections governing mineral development, timber sales, and ski area expansion, none of which relate to fire. The DEIS does not explain why that is necessary. This makes the range of alternatives inadequate under NEPA. The Department has not analyzed an alternative that broadens the fire and fuels exceptions while keeping road construction prohibitions in place. Idaho and Colorado both have state-specific roadless rules built for exactly that purpose. I request that a Utah-specific alternative, or a targeted amendment to 36 CFR 294.13, be analyzed in the final EIS. The DEIS should also identify how many acres of planned, funded fuels treatment on this forest have actually been blocked by the rule since 2001. Without that, the purpose and need is unsupported. Most Wasatch roadless terrain is steep and high elevation, where roads are impractical and treatment does little for structures along the Wasatch Front. Finally, roughly 80 percent of Salt Lake City's watershed sits within this forest. Forest roads are a leading source of sediment in forested watersheds, and the DEIS does not adequately analyze that risk to the drinking water of over a million people. Please retain the 2001 Roadless Rule. Christian Purdy

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