Comment Analysis · Docket FS-2025-0001

FS-2025-0001-317870

Opposes rescissionA1 strongSubstance 13/24Owed an answerPosted September 7, 2026 On Regulations.gov

In short: The comment documents the absence of environmental justice screening in the Draft EIS for a rule affecting 44.7 to 58 million acres, cites specific noise pollution data from Buxton et al. (2017) regarding protected areas, and requests a dedicated Environmental Justice section under NEPA 42 U.S.C. § 4332(2)(C) for communities near roadless areas in the Wasatch-Cache National Forest.

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, 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

  • Climate Carbon Storage
    • “quiet contribution to forest carbon retention”
    • “rescission misses it anyway”
    • “follow climate as I do”
  • Wildlife Habitat
    • “natural beauty and wildlife of this area deserves the utmost respect and conservation”
    • “decrease in wildlife in an already dwindling population”
    • “local wildlife areas be potentially threatened”
  • Recreation Tourism Public Use
    • “enjoying the wilderness right in my backyard”
    • “lose access to isolated get-away locations”
    • “Quiet, undeveloped recreation on roadless lands supports local economies”
  • Governance Policy Process
    • “Complete Absence of Environmental Justice Screening Methodology”
    • “NEPA's hard-look mandate”
    • “I request a dedicated Environmental Justice section”

What it names

National Forests
Wasatch-Cache National Forest
Roadless areas
Twin Peaks
Law cited
Executive Order 12898
Works cited
10.1126/science.aah4783

The comment

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

To the Roadless Rule Rulemaking Team: If you follow climate as I do — daily, reluctantly — the 2001 Rule's quiet contribution to forest carbon retention is hard to miss. The rescission misses it anyway. I am local to the Wasatch National Forest, these areas have been a huge part of my life enjoying the wilderness right in my backyard. I hope to raise my own family in this area, and I believe the natural beauty and wildlife of this area deserves the utmost respect and conservation. Not only this, but the utah's wildlife and outdoors are already under fire and deserve more protection than ever. Hiking to Red Pine Lake with my girlfriend, enjoying the cold water and cooler temperatures. Being isolated, away from all the noise of the city such as road noise, generators, and even the simple noises from a suburban city. With the roadless rule being removed, we could see a decrease in wildlife in an already dwindling population. We may also lose access to isolated get-away locations that many choose for a sanctuary. Regarding the Twin Peaks in the Wasatch-Cache National Forest, Utah: Quiet, undeveloped recreation on roadless lands supports local economies through tourism, outfitting, hunting, and fishing. Road noise reaches deep into protected areas. Anthropogenic noise doubles background sound levels in 63 percent of U.S. protected area units and produces a tenfold increase in 21 percent of them. Elevated noise was found in habitats of endangered species, with 14 percent of critical habitats experiencing a tenfold sound increase. Noise pollution in protected areas is closely linked with transportation, development, and extractive land use (Buxton et al. 2017). — Buxton et al., 2017 (https://doi.org/10.1126/science.aah4783) Rescinding the Roadless Rule would open the Twin Peaks, Wasatch-Cache National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. Rolling back the roadless rule is an ignorant action that will hurt many areas of the outdoors. The roadless rule is a necessary piece of law that protects some of the areas closest to all of our hearts. I am terrified to see my local wildlife areas be potentially threatened by a misguided attempt to take away our public lands. Complete Absence of Environmental Justice Screening Methodology (EJScreen/CEJST) Nationwide The Draft EIS provides no environmental justice screening for a rulemaking that could affect up to 44.7 to 58 million acres nationwide. The Purpose and Need section states only that the agency "prioritizes decisionmaking by local Forest Service officials informed by Tribes, State, and local communities," and the Socioeconomic discussion documents "starkly divergent impacts" between resource-dependent rural communities and recreation-dependent "gateway communities" facing "job losses, mill closures and economic instability." Nowhere is this divergence overlaid with EJScreen, the Climate and Economic Justice Screening Tool, or any comparable demographic analysis identifying low-income or minority populations affected by increased logging, road construction, or mineral leasing. NEPA's hard-look mandate, 42 U.S.C. § 4332(2)(C), requires analysis of the disproportionate community burdens the DEIS's own socioeconomic findings place at issue — a statutory duty unaffected by the January 2025 revocation of Executive Order 12898 — and EPA's 2025 Interim Environmental Justice Framework reflects continuing agency practice of exactly this screening. I request a dedicated Environmental Justice section, distinct from Tribal consultation discussion, screening communities near operable roadless areas, wildland-urban interface zones, and mineral-lease tracts under every alternative. The forests these rules cover deserve to stay roadless. I'm asking the Department to keep them that way. With respect, CommentID: RLC-20260905-GLIHTX

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