Comment Analysis · Docket FS-2025-0001

FS-2025-0001-485421

Opposes rescissionA1 strongSubstance 15/24Owed an answerPosted September 28, 2026 On Regulations.gov

In short: The comment documents that the agency's draft EIS contains internal contradictions regarding wildfire risk and road density, that the regulatory flexibility analysis improperly averages economic losses across the national sector rather than assessing specific local small entities, and that the rescission ignores documented reliance interests in the stability of the 2001 Roadless Rule for local trail management and water quality protection in Cache County.

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

A1 strong: Must be answered — it names the law.

Owed an answer on Analytical gap, Legal.

Standard dismissals it defeats

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.
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.
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.

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.
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.

Topics

Recreation Tourism Public Use
- “quiet, photograph clear mountain streams and high ridgelines with no visible sign of human impact”
- “I have been hiking in and around Mt. Logan South... for almost 8 years”
- “lost recreation benefit at a minimum of $6.1 million a year”
- “It makes sense to allow different areas to serve different recreation and access needs”
Water Quality Quantity
- “The water quality in that marsh begins in these roadless areas”
- “1,466 municipal water intakes sit in watersheds containing affected roadless areas”
- “fed by the Logan River and the Blacksmith Fork River, both of which have their headwaters in Cache National Forest”
Wildlife Habitat
- “where wild animals still gather and thrive away from modern development and machines”
- “I have seen all kinds of wildlife who still call this yet unfragmented place home”
- “less diversity in the animals you are likely to see”
Governance Policy Process
- “I ask that the agency reconcile this contradiction”
- “I ask that the agency withdraw that certification and assess impacts on the specific small entities”
- “The proposal overstates what the rule prohibits”

What it names

National Forests: Caribou National Forest Uinta National Forest Wasatch-Cache National Forest
Law cited: 36 C.F.R. Section 294.12

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeAnalytical gapEvidenceRequest

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Cache National Forest is my backyard. I hike throughout Utah, but the mountains above Cache County are where I find quiet, photograph clear mountain streams and high ridgelines with no visible sign of human impact, where wild animals still gather and thrive away from modern development and machines. Cutler Marsh in Cache County is where I paddle, fed by the Logan River and the Blacksmith Fork River, both of which have their headwaters in Cache National Forest, and by the Bear River, with headwaters in the Uinta National Forest. The water quality in that marsh begins in these roadless areas. I oppose the rescission of the 2001 Roadless Area Conservation Rule as proposed in Docket FS-2025-0001. I serve as the Cache County Trails and Active Transportation Coordinator. In that role I have seen what good local/federal partnership looks like. In the Wellsville Mountains, 1,717 acres in the Wasatch-Cache National Forest, I spent years working on a project with the county to open additional access for hikers, campers, and horseback riders through a new trailhead. Access into those mountains is not a federal problem. This should be a local-led effort and we have made big strides locally with Forest Service support and without touching the roadless character of the land. Around Clarkston Mountain, 7,099 acres in the Caribou National Forest, I have been working to preserve existing roads already in the area. With those existing roads preserved there will be plenty of access and recreation opportunities with no need to impact or change the existing roadless portions. The Mt. Logan roadless area is different in what would be lost. I have been hiking in and around Mt. Logan South (17,014 acres), Mt. Logan North (18,930 acres), and Mt. Logan West (5,285 acres), all in the Wasatch-Cache National Forest, for almost 8 years. I have spent many Saturdays maintaining trails and helping people with disabilities get out and enjoy them. I have seen all kinds of wildlife who still call this yet unfragmented place home. To the south of this area there is already land crisscrossed with roads, and hiking there is a very different experience, with less diversity in the animals you are likely to see and the constant noise of machines. It makes sense to allow different areas to serve different recreation and access needs rather than making the whole of our wild lands look and feel the same. The agency's own record makes this concern concrete. Its draft environmental impact statement states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal nonetheless justifies rescission partly on wildfire and fuels management grounds. I ask that the agency reconcile this contradiction: explain specifically why the proposal departs from its own prior findings on fire occurrence, and reconcile the rescission with the ignition data in its own DEIS, which reports higher fire density on roaded land than inside the affected roadless areas. The proposal overstates what the rule prohibits. The agency's own text notes that the rule "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." If the justification for rescission is permitting burden and administrative difficulty, I ask that the agency identify which burdens are not already addressed by those existing exceptions and quantify those burdens with specificity on the record. Utah holds 222 inventoried roadless areas totaling 4,013,529 acres. Across the Intermountain region, 1,466 municipal water intakes sit in watersheds containing affected roadless areas. The proposed rescission's own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year, yet the regulatory flexibility analysis certifies no significant impact on small entities by averaging that loss across every small firm in the sector nationally rather than examining the outfitters, guides, and tour operators actually holding permits in these areas. I ask that the agency withdraw that certification and assess impacts on the specific small entities operating in potentially affected roadless areas. 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 work coordinating trails and access in Cache County, the public investment in the Wellsville trailhead, and the years of volunteer trail maintenance in the Mt. Logan roadless areas rested on the assumption this rule would hold. Sincerely, Landis Wenger Logan, Utah