Comment Analysis · Docket FS-2025-0001

FS-2025-0001-325778

Opposes rescissionA3 weakSubstance 9/24Owed an answerPosted September 7, 2026 On Regulations.gov

In short: The comment documents a specific first-hand observation in the Cache National Forest where the roadless Mount Naomi Wilderness Area produced clear water while surrounding roaded and logged drainages produced muddy water, supporting the argument that rescinding the 2001 Roadless Rule would negatively impact water quality and increase wildfire risks.

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 Evidence.

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

Wildlife Habitat
- “fragment wildlife habitat”
- “disrupt elk calving, deer and moose birthing areas”
- “destroy a lot of the few remaining sanctuary areas wildlife needs to remain viable and healthy”
Water Quality Quantity
- “impacts to water quality”
- “protect a large number of our country's clean water sources”
- “streams were running high and muddy until we got to High Creek, and it was running high and clear”
Forest Management Wildfire
- “Opening roadless areas to timber harvesting will NOT help... reduce wildfire risks”
- “elevating not reducing wildfire risks”
- “increased road access elevating the risk of human-caused fires”
Economic Impact Fiscal
- “small short-lived benefit to local economies, with little to no long-term economic gain”
- “timber in the Roadless areas would be below-cost sales”
- “costs of building the roads... make the roadless areas economically unprofitable”

The comment

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

Dear Chief Tom Schultz, Please do not rescind the 2001 Roadless Area Conservation Rule. We want all of our Roadless Areas left intact. Opening roadless areas to timber harvesting will NOT help lower the cost of wood construction materials nor reduce wildfire risks, that justification is ludicrous. The Roadless Act protects remote areas. There are also the Forest and Rangeland Renewable Resources Planning Act of 1974 (RPA). Congress amended the RPA by enacting The National Forest Management Act of 1976 (NFMA). This legislation is well researched and documented with public support. It is fully supported by years of study by hundreds of wildlife, fishery and rangeland biologists. The environmental damage caused by building new roads will be significant. There will be impacts to water quality, wildlife habitat, and there is a high risk of the introduction of invasive plants and insects elevating not reducing wildfire risks. There will be a small short-lived benefit to local economies, with little to no long-term economic gain. Wildfire fuels reduction from timber harvests would be offset by the increased road access elevating the risk of human-caused fires in more remote limited access areas. In the past four decades ATV and UTV operators have proven they do not stay on. Opening new roads will generate numerous braided trails and will cause more damage and further fragment wildlife habitat. The increased use will disrupt elk calving, deer and moose birthing areas, and the noise and activity will destroy a lot of the few remaining sanctuary areas wildlife needs to remain viable and healthy. Most Roadless Areas in the U.S. are roadless because the costs of building the roads to access the timber and administration costs to oversee the harvest make the roadless areas economically unprofitable. Most of the timber in the Roadless areas would be below-cost sales, most of which would occur in locations where costs are high because of the need to build an access road, and when the volume or value of the harvested timber is low. The 2001 Roadless Area Conservation Rule (Roadless Rule) should be kept. It is a needed protection for the health of our forest lands and currently helps to protect a large number of our country’s clean water sources. One spring, while I was working grading roads on the Cache National Forest in the Blacksmith Fork River drainage area of Cache County Utah, it started raining. Soon the road got too wet to grade. It continued to rain for the next several days so we started doing other types of road maintenance work in the local drainage basins. All of the streams were running high and muddy until we got to High Creek, and it was running high and clear. What made that stream different? High Creek drains out of Mount Naomi Wilderness Area (a roadless un-logged area). All of the surrounding drainage areas with muddy streams had roads and most of those the timber had been cut, some multiple times. Without exception, every drainage with roads in them the streams were muddy, some worse than others. High Creek’s drainage basin is currently roadless, and hopefully will remain so. This is one event I personally witnessed. It changed the way I drained the roads I graded roads for the rest of my career. I worked as an operator first and supervisor later for the Construction and Maintenance crew on the Uinta Wasatch Cache National Forest in northern Utah. Best regards Craig Weir Millcreek, UT 84124 801 580-6438