Comment Analysis · Docket FS-2025-0001

FS-2025-0001-529989

Opposes rescissionA0 noneSubstance 8/24Posted October 1, 2026 On Regulations.gov

In short: The comment documents specific deficiencies in the Draft EIS regarding wildfire and economic analysis, cites the 2001 Roadless Area Conservation Rule, and requests the Forest Service select the No Action alternative based on impacts to Utah's roadless areas and public comment process inadequacies.

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

Forest Management Wildfire
- “The agency's own analysis does not support the wildfire argument”
- “Wildfire ignitions increase as road density increases”
- “The current rule already allows thinning, and even road building, to reduce wildfire risk”
Water Quality Quantity
- “Roadless areas protect drinking water”
- “Road building and logging in source watersheds degrade water quality”
- “raise filtration costs for the people downstream”
Recreation Tourism Public Use
- “Recreation supports far more of the economy than logging”
- “Hunting, fishing, hiking, biking and skiing do not need new roads”
- “they lose value when backcountry is roaded and logged”
Governance Policy Process
- “The process is inadequate”
- “This rescission allows a short comment period and holds no public hearings”
- “A rule built with that much public input should not be undone with this little”

What it names

National Forests: Dixie National Forest
Roadless areas: Little Cottonwood

Attachments

1 file. Counts as 1 — Counts as one: The attachments enclose no one else's submissions; the comment counts as one.

Own letter

The comment

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

Re: Special Areas; Roadless Area Conservation – Proposed Rescission and Draft EIS My name is Chris Cochella a long time user of our public lands to raft, kayak, bicycle, hike and simply enjoy. I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. I urge the Forest Service to choose the No Action alternative in the final EIS. I live in Utah. About 4 million acres here, nearly half of our national forest land, are inventoried roadless areas. They include the backcountry of Big and Little Cottonwood, Millcreek and American Fork canyons, the Uintas, and the Dixie National Forest. I have traveled many miles of existing Forest Service roads by car, bike and on foot. We have plenty of roads. What we can't make more of is intact backcountry. 1. The agency's own analysis does not support the wildfire argument. The Draft EIS acknowledges three things: Wildfire ignitions increase as road density increases. Roadless areas currently have fewer fire starts than other national forest lands. Any gain in fuel-treatment capacity from rescission would be "modest." Most wildfires are human-caused, and most start near roads. The current rule already allows thinning, and even road building, to reduce wildfire risk or protect public safety. About 2 million roadless acres have already been treated under it. The fires that destroy homes burn in the wildland-urban interface, which already has roads. New roads in remote backcountry protect few structures and add new sources of ignition. 2. Taxpayers cannot afford more roads. The Forest Service already has a deferred maintenance backlog of roughly $7 billion on the roads it has now. The DEIS admits that timber revenue would not cover the cost of building and maintaining the new roads that rescission would allow. The projected $5–11 million a year in new timber revenue nationwide is small compared with that cost. Unmaintained roads also erode, sending sediment into streams and fisheries. 3. Roadless areas protect drinking water. These areas protect hundreds of municipal watersheds. Along the Wasatch Front, the Cottonwood canyons are a drinking water source for the Salt Lake Valley. Road building and logging in source watersheds degrade water quality and raise filtration costs for the people downstream. 4. Recreation supports far more of the economy than logging. Recreation is the single largest part of the national forests' economic contribution. It produces more jobs and more GDP than timber. Utah's outdoor recreation industry is worth billions a year. Moab is a good example. It used to be a dusty mining town and is now a thriving recreation economy. Hunting, fishing, hiking, biking and skiing do not need new roads, and they lose value when backcountry is roaded and logged. 5. Rescission is not a neutral return to "local control." Most of Utah's roadless acres sit in areas where current forest plans would allow road construction. For tens of millions of acres nationwide, the Roadless Rule is the only thing preventing new roads. Removing it is not a simple handoff to local managers. It removes the only protection these lands have. 6. The process is inadequate. The 2001 rule was developed through more than 600 public meetings and a 120-day comment period, and it drew about 1.6 million comments. This rescission allows a short comment period and holds no public hearings. A rule built with that much public input should not be undone with this little. The Roadless Rule has worked for 25 years. It balances wildfire management, clean water, wildlife and recreation, and its existing exceptions already allow the work the agency says it needs to do. Please keep it in place.