Comment Analysis · Docket FS-2025-0001

FS-2025-0001-361558

Opposes rescissionA0 noneSubstance 4/24Posted September 12, 2026 On Regulations.gov

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

Environmental Protection Biodiversity
- “ecological integrity”
- “Pando, the remarkable aspen clone”
- “living ecological systems”
- “fragmentation that may be impossible to reverse”
Wildlife Habitat
- “alter habitat”
- “wildlife movement”
- “absence of development is itself part of what we are protecting”
- “uninterrupted landscape”
Water Quality Quantity
- “alter... watersheds”
- “fragment it”
- “roads and development fragment it”
Governance Policy Process
- “consistent national safeguard”
- “decisions made project by project or forest by forest”
- “retain the 2001 Roadless Area Conservation Rule”

What it names

National Forests: Fishlake National Forest

The comment

I strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. I have personally spent time in Utah’s extraordinary public lands, including the Grand Staircase-Escalante region, and the experience profoundly affected me. There are places where the absence of development is itself part of what we are protecting. The scale, silence, ecological integrity, and sense of uninterrupted landscape cannot simply be recreated once roads and development fragment it. I am also deeply concerned about the future of Utah’s Fishlake National Forest, including Pando, the remarkable aspen clone that represents one of the world’s largest known living organisms. Places like this are not ordinary parcels of land. They are living ecological systems whose value extends far beyond any immediate commercial use. The Roadless Rule provides a consistent national safeguard for inventoried roadless areas. Replacing that protection with decisions made project by project or forest by forest creates the possibility of fragmentation that may be impossible to reverse. Roads do not affect only the ground beneath them. They can alter habitat, watersheds, wildlife movement, fire and invasive-species dynamics, and the character of landscapes that have remained largely undeveloped. These lands also belong to generations who have not yet had the opportunity to experience them. I was fortunate enough to stand in the landscapes of southern Utah and experience something that I still carry with me. Future generations deserve that same possibility. I respectfully request that the Forest Service retain the 2001 Roadless Area Conservation Rule and its nationwide protections for inventoried roadless areas, including roadless lands within Utah’s National Forests. Some places have value precisely because we have chosen not to build through them. Once that continuity is lost, we cannot assume we will ever get it back. Warmly, Katrina Elkins San Francisco CA