Comment Analysis · Docket FS-2025-0001

FS-2025-0001-367911

Opposes rescissionA2 moderateSubstance 13/24Owed an answerPosted September 12, 2026 On Regulations.gov

In short: The comment places on the record specific data from the agency's DEIS (Table 21, grizzly bear recovery plan, and Cost Benefit Analysis) to demonstrate that the proposed rescission contradicts the agency's own findings on fire ignition risks, administrative burdens, and economic impacts, while failing to address the specific reliance interests in Utah's roadless areas that the agency solicited.

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

A2 moderate: Hard to dismiss — it shows cause and effect.

Owed an answer on Analytical gap, 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.
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.

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.
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
- “Undeveloped land is where I go to feel in touch with nature”
- “I hike and camp in places like Mineral Canyon and Bear Valley Peak”
- “lost recreation benefit at a minimum of $6.1 million a year”
- “outfitters, guides and tour operators as affected”
Forest Management Wildfire
- “The wildfire rationale the agency offers does not survive contact with its own data”
- “roads allow more agile positioning of firefighting assets, they are also the site of high rates of human-caused ignition”
- “Opening roadless areas... would bring exactly that ignition risk”
- “reconcile the rescission with those ignition figures in its own record”
Wildlife Habitat
- “concern about what new roads do to wildlife”
- “increased contact and conflict in grizzly habitat from open roads can ultimately end in grizzly mortality”
- “shooting, habituation, and food reward all increase with use of even secondary unpaved roads”
- “Bear Valley Peak offers a range of plants that is a pleasure to see”
Governance Policy Process
- “The agency must identify, specifically and quantitatively, which burdens remain unaddressed”
- “The agency should withdraw that certification and assess the firms actually operating”
- “The agency invited reliance interests and then ignored them”
- “The agency must identify and weigh the interests described in the comments”

What it names

National Forests: Dixie National Forest
Roadless areas: Bear Valley PeakMineral Canyon
Works cited: Narayanaraj and Wimberly 2012U 1993

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Undeveloped land is where I go to feel in touch with nature and get away from the stress of daily life. I hike and camp in places like Mineral Canyon and Bear Valley Peak, both inventoried roadless areas in the Dixie NF in Utah. Mineral Canyon's red rocks draw me in part because it is much less congested than Zion and Bryce. Bear Valley Peak offers a range of plants that is a pleasure to see. These places matter to me, and the proposal to rescind the 2001 Roadless Area Conservation Rule would put them at risk. I oppose that rescission. The wildfire rationale the agency offers does not survive contact with its own data. The agency's draft environmental impact statement states: "While roads allow more agile positioning of firefighting assets, they are also the site of high rates of human-caused ignition (Narayanaraj and Wimberly 2012), which account for 84% of US wildfires (Balch et al 2017)." Opening roadless areas like the ones I visit to new road construction would bring exactly that ignition risk into places that currently carry lower fire density than roaded land, as the agency's own DEIS Table 21 shows. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence in roadless areas, and reconcile the rescission with those ignition figures in its own record. The agency also claims the current rule creates administrative and permitting burdens, but the rule as written already accommodates the activities the agency says it cannot do. The DEIS states: "The rule recognizes the need for tree cutting to reduce the risk of wildfire to at-risk communities. It allows tree cutting in non-upper tier within 0.5 miles from the boundary of an at-risk community, or up to 1.5 miles if certain conditions exist and the area is within a Community Wildfire Protection Plan (CWPP). A temporary road may be constructed to facilitate hazardous fuel reduction within 0.5 miles of the boundary of an at-risk community." If the rule already permits these actions, the agency must identify, specifically and quantitatively, which burdens remain unaddressed by the existing exceptions for public health and safety, existing mineral leases, and community wildfire protection. That accounting belongs in the record before any rescission proceeds. I also hike where bears live, and that connection sharpens my concern about what new roads do to wildlife. The DEIS cites the federal grizzly bear recovery plan for the finding that increased contact and conflict in grizzly habitat from open roads can ultimately end in grizzly mortality, and that shooting, habituation, and food reward all increase with use of even secondary unpaved roads. The places I walk in Utah are part of a larger landscape. Utah holds 222 inventoried roadless areas totaling 4,013,529 acres, and across the Intermountain region, which includes Utah, 1,466 municipal water intakes sit in watersheds containing affected roadless areas. The cumulative exposure created by rescission, for wildlife and for water, deserves a serious response from the agency in this docket. On economic impact, the agency's own record undermines the regulatory flexibility certification. "The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year." Spreading a $9 million annual expenditure loss across every small firm in the sector nationally, rather than examining the outfitters and guides actually permitted in the affected areas, does not constitute a meaningful analysis. The agency should withdraw that certification and assess the firms actually operating in these roadless areas. Finally, the agency invited reliance interests and then ignored them. "The proposal solicits 'any reliance interests in the current rule that could be affected by this proposal' (91 FR 53830-31), and the Cost Benefit Analysis weighs none." My use of Mineral Canyon and Bear Valley Peak, and my expectation that they remain undeveloped, is exactly the kind of reliance interest the agency asked about. The agency must identify and weigh the interests described in the comments it receives, including this one, before it can lawfully change course. Sincerely, Sanford Krasner Altadena, CA