Comment Analysis · Docket FS-2025-0001

FS-2025-0001-559291

Opposes rescissionA2 moderateSubstance 14/24Owed an answerPosted October 5, 2026 On Regulations.gov

In short: The comment establishes that the agency's proposed rescission of the Roadless Area Conservation Rule contains internal contradictions regarding wildfire risk and economic justification, fails to properly assess localized impacts on small businesses in Utah, and neglects to weigh reliance interests created by the prior rule.

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

A2 moderate: Hard to dismiss — it shows cause and effect.

Owed an answer on Analytical gap, Evidence.

Standard dismissals it defeats

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.

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.
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.
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
- “Twenty years of guiding river rafting and mountain biking trips”
- “close working relationship with the landscapes this proposal would put at risk”
- “lost recreation benefit at a minimum of $6.1 million a year”
- “built a guiding career in part around the character and accessibility of roadless terrain”
Forest Management Wildfire
- “wildfire rationale offered for this rescission conflicts directly with the agency's own findings”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “Opening them to roads in the name of fire management”
- “reconcile the rescission with the ignition data its own analysis produced”
Economic Impact Fiscal
- “The economic case for rescission is not established by the record”
- “net present value range spanning -$92 million to +$199 million”
- “Forest Service is already carrying a $6.9 billion road maintenance backlog”
- “does not constitute a reasoned economic justification”
Water Quality Quantity
- “sit inside watersheds that are already under pressure”
- “1,466 municipal water intakes sit in watersheds containing affected roadless areas”
- “water users across that landscape”

What it names

Roadless areas: Lone Peak ContiguousTwin PeaksWhite Pine

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Twenty years of guiding river rafting and mountain biking trips, combined with my own backcountry skiing, have given me a close working relationship with the landscapes this proposal would put at risk. The inventoried roadless areas of the Wasatch-Cache and Uinta National Forests in Utah, including Mt. Olympus, Mt. Aire, Twin Peaks, Lone Peak Contiguous, White Pine, and White Baldy, are the kind of terrain I depend on professionally and personally. I am opposing rescission of the 2001 Roadless Area Conservation Rule under Docket FS-2025-0001. The wildfire rationale offered for this rescission conflicts directly with the agency's own findings. The record 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 areas I guide and ski in Utah, including the roadless terrain of the Wasatch-Cache, sit inside watersheds that are already under pressure. Opening them to roads in the name of fire management, when the agency's own DEIS Table 21 documents far higher fire density on roaded land, is a contradiction that demands a direct answer. I ask that the agency explain why this proposal departs from those prior findings and reconcile the rescission with the ignition data its own analysis produced. The economic case for rescission is not established by the record. The agency itself acknowledges that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against that marginal extraction potential, the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of only $5.2 to $11.4 million a year, offset by recreation losses of at least $6.1 million a year, with a net present value range spanning -$92 million to +$199 million. The Forest Service is already carrying a $6.9 billion road maintenance backlog. Expanding a road system that cannot be maintained, in order to capture a share of national production measured in fractions of a percent, does not constitute a reasoned economic justification. The agency must explain on the record how an action whose own Cost Benefit Analysis cannot establish a net benefit justifies that expansion. As a guide and outfitter operating in these landscapes, I am directly named in the agency's own analysis. The proposed rule certifies no significant impact on small entities, yet the DEIS identifies outfitters, guides, and tour operators as affected parties, and the Cost Benefit Analysis records lost recreation benefit at a minimum of $6.1 million a year. The regulatory flexibility analysis reaches its no-impact conclusion by distributing an annual expenditure loss of $9 million across every small firm in the sector nationally, rather than examining the outfitters and guides who actually hold permits in the affected areas. That approach conceals localized harm behind a national average. The agency should withdraw the small-business certification and conduct an assessment focused on the specific entities operating under permits in the potentially affected roadless areas, not the industry as a whole. Finally, 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. I have built a guiding career in part around the character and accessibility of roadless terrain in Utah. Utah alone holds 222 inventoried roadless areas totaling 4,013,529 acres, and across the Intermountain region 1,466 municipal water intakes sit in watersheds containing affected roadless areas. The rule's protections have shaped decisions by guides, businesses, communities, and water users across that landscape for more than two decades. An agency changing course is required to identify and weigh the reliance interests its prior policy created. The agency must account for those interests, including the ones described in this comment, before any final action. Sincerely, Colin Gaylord Salt Lake City, Utah