Opposes rescissionA0 noneSubstance 4/24Posted September 16, 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 eliminatedThe agency says it considered and eliminated the alternative the comment proposes, with a reason. Cannot be defeated from the comment text alone.
Already addressedThe 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 decisionThe agency says the point belongs to a later, site-specific decision. Cannot be defeated from the comment text alone.
Misreads the proposalThe agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
Not requiredThe agency says the analysis the comment asks for is not required. Cannot be defeated from the comment text alone.
Preference notedThe 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 shownThe agency says the comment asserts a harm without showing how the action causes it. Defeated when the comment shows the mechanism.
Outside the scopeThe agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.
Certified not substantiveThe agency certifies the comment raises nothing substantive. Defeated when the comment alleges illegality, which is substantive by the definition the certification runs on.
I recently visited southern Utah and drove through the extraordinary landscape around Grand Staircase-Escalante and Dixie National Forest. What struck me most was the vast expanse of unpeopled, undeveloped land stretching as far as I could see. I had never seen anything like it. The views were breathtaking in large part because there were so few visible signs of human development.
These landscapes are priceless and irreplaceable. Their extraordinary rock formations and sweeping vistas cannot simply be reconstructed once they have been physically altered by roads or development. We can't fix it if we break it.
I was also struck by how many international visitors were there. During our trip, I heard people speaking French and Italian. People are traveling from other countries to experience this landscape because it is so extraordinary. Preserving its undeveloped character protects one of the very qualities that draws people to southern Utah in the first place.
For the roadless areas in Dixie National Forest, I am particularly concerned about permanent visual and physical alteration from road construction. These areas should remain roadless. Some places are treasures precisely because we have left them alone, and this is one of those places.
I urge the Forest Service to retain Roadless Rule protections rather than rescind them.