Comment Analysis · Docket FS-2025-0001

FS-2025-0001-413100

Opposes rescissionA0 noneSubstance 6/24Posted September 15, 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

  • Recreation Tourism Public Use
    • “As a hiker, backpacker, employee of the outdoor industry”
    • “Outdoor recreation and tourism is essential to our state's economy”
    • “Wilderness recreation generates an estimated $574 million annually in economic value”
    • “Please leave these spaces wild for those who enjoy them”
  • Environmental Protection Biodiversity
    • “Each of these areas are home to hundreds of species”
    • “The Roadless Rule protects these spaces from logging and industry development”
    • “directly affect me, my family, and the environment we love so much”
  • Forest Management Wildfire
    • “Opening up these spaces will also not help with wildfire suppression”
    • “wildfire ignition density within 50 meters of roads is roughly four times higher”
    • “A century of aggressive fire suppression, made possible by road access, has degraded fire-dependent forests”
  • Economic Impact Fiscal
    • “shift from extraction-based growth to amenity-based growth”
    • “Counties with substantial protected federal lands have grown faster in population, employment, and per capita income”
    • “documents an $8.4 billion deferred maintenance backlog across the existing road network”

What it names

Roadless areas
Ponderosa Pine

The comment

Hello, I oppose full rescission of the Roadless Rule. As a hiker, backpacker, employee of the outdoor industry, and someone who calls Utah home, pulling back these restrictions would directly affect me, my family, and the environment we love so much. From our zipcode alone, there are over 50 areas that would be affected by the Roadless Rule's end. Each of these areas are home to hundreds of species and make Utah special. Outdoor recreation and tourism is essential to our state's economy and my work as a marketer in the outdoor space. The Roadless Rule protects these spaces from logging and industry development. Research on Western U.S. economies describes a shift from extraction-based growth to amenity-based growth. Counties with substantial protected federal lands have grown faster in population, employment, and per capita income than counties without — with growth concentrated in lodging, dining, and professional services (Izon et al. 2010; Holmes & Hecox 2002). Wilderness recreation generates an estimated $574 million annually in economic value, and Western wilderness passive-use value is estimated at roughly $168 per acre (Loomis 2000). The Forest Service's own road-management strategy documents an $8.4 billion deferred maintenance backlog across the existing road network — a backlog the agency has acknowledged it cannot resolve. Expanding the road network into roadless areas would compound this maintenance burden (USDA Forest Service 2001 EA). Opening up these spaces will also not help with wildfire suppression. A 2026 study of three decades of National Forest System wildfire data found that wildfire ignition density within 50 meters of roads is roughly four times higher than in non-wilderness, non-roadless forest. Wilderness and Inventoried Roadless Areas have the lowest ignition densities of any land category studied (Aplet et al. 2026). Most ignitions near roads are human-caused; lightning-caused fires are concentrated away from roads (Narayanaraj & Wimberly 2012). A century of aggressive fire suppression, made possible by road access, has degraded fire-dependent forests by removing the periodic low-intensity fire that longleaf pine, ponderosa pine, and similar systems evolved with (USDA Forest Service 2001). Please leave these spaces wild for those who enjoy them and those who live there. Thank you

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