Comment Analysis · Docket FS-2025-0001

FS-2025-0001-514554

Opposes rescissionA0 noneSubstance 8/24Posted September 29, 2026 On Regulations.gov

In short: The comment documents local opposition to the rescission of the Roadless Area Conservation Rule in the Wasatch-Cache National Forest, citing specific DEIS findings regarding increased sediment, fire risk, and negative net present value, while asserting standing based on residence near Salt Lake City and reliance on local watersheds.

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

  • Water Quality Quantity
    • “Negative effects to watersheds with potential for increased sediment and faster runoff”
    • “Salt Lake's water comes from watersheds in the canyons”
    • “I want to continue to have safe drinking water - and enough of it”
    • “skid roads, trails and log landings... are the main cause of soil erosion”
  • Recreation Tourism Public Use
    • “diminishes the experience and quality of the environment for recreational users”
    • “less tourism dollars and users as well as a degraded environment”
    • “maintains the most opportunities for quiet, remote and self-reliant recreation”
    • “I want to be able to enjoy hiking and photographing in these areas”
  • Environmental Protection Biodiversity
    • “More invasive species and harm to native species - both plants and animals”
    • “More construction and logging, which diminishes the experience and quality of the environment”
    • “These lands need to be managed responsibly”
    • “We are stewards of them for future generations”
  • Economic Impact Fiscal
    • “The Forest Service can't afford to maintain their existing roads”
    • “Maximum projected timber revenue is $5.2 to 11.4 million a year, against up to $6.1 million a year in lost recreation benefit”
    • “net present value that runs to negative $92 million”
    • “road mileage, deferred maintenance and management costs are likely to increase”

What it names

National Forests
Wasatch-Cache National Forest

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequestAlternativeLegal

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I live near Salt Lake City and numerous areas that could be affected by rescinding the rule. This includes the Wasatch-Cache National Forest and the wilderness area near Mt. Olympus, which is just up the road. I am opposed because rescinding the rule could lead to the following: - More human caused fires. The Forest Service’s DEIS analysis showed this. Fire mitigation through alternatives other than roads should be explored first. - More construction and logging, which diminishes the experience and quality of the environment for recreational users. This could lead to less tourism dollars and users as well as a degraded environment. The DEIS concedes the no-action alternative maintains the most opportunities for quiet, remote and self-reliant recreation, and that under rescission the settings could shift toward more developed conditions. - More invasive species and harm to native species - both plants and animals. See https://biologicaldiversity.org/programs/public_lands/pdfs/Deadly-Incursions-report.pdf - Negative effects to watersheds with potential for increased sediment and faster runoff with more roads. Salt Lake’s water comes from watersheds in the canyons. Right now that water is clean: less than 12 percent of the watersheds containing these areas have impaired streams. By the Forest Agency’s own analysis, the skid roads, trails and log landings that come with timber harvest are the main cause of soil erosion and can contribute up to 90 percent of the sediment generated by timber sale activity. - The Forest Service can’t afford to maintain their existing roads. Road appropriations fell from $234 million in 2004 to $73 million in 2024, against a $6.9 billion deferred maintenance backlog. The supplemental funding is expiring. Maximum projected timber revenue is $5.2 to 11.4 million a year, against up to $6.1 million a year in lost recreation benefit by its own figures, and the agency’s own cost-benefit analysis states a net present value that runs to negative $92 million. The DEIS states outright that road mileage, deferred maintenance and management costs are likely to increase. I want to continue to have safe drinking water - and enough of it. I want to be able to enjoy hiking and photographing in these areas. These lands need to be managed responsibly. We are stewards of them for future generations. Thank you.

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