Comment Analysis · Docket FS-2025-0001

FS-2025-0001-561161

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

Small family — One letter sent by 3 to 9 people, copied or lightly reworded. One of 3 submissions in its group. See the letter, its submissions and topics.

In short: The comment establishes that the rescission of the 2001 Roadless Rule would irreversibly fragment specific inventoried roadless areas in the Ashley National Forest and Flaming Gorge National Recreation Area, degrading water quality, wildlife habitat, and the recreation-based economy of Daggett County, and requests the retention of these protections or the adoption of narrowly tailored exceptions.

Scored as the letter — The shared letter of a family, scored once for everyone who sent it.

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, Alternative.

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
- “Visitors come here for Flaming Gorge, fishing, hunting, wildlife, camping, hiking, scenery”
- “recreation associated with Flaming Gorge, the Green River, hunting, fishing, wildlife viewing, camping, hiking, and scenic landscapes is an important part of both the community's identity and economy”
- “reduce the quiet, remote recreational character that makes these lands valuable”
- “exchange a long-term renewable recreation asset for short-term development benefits”
Water Quality Quantity
- “Protecting intact watersheds should remain an important preventative management tool for maintaining water quality”
- “reducing erosion, and protecting vegetation and wildlife habitat”
- “increase erosion and sedimentation”
- “watershed integrity”
Wildlife Habitat
- “Roads can fragment wildlife habitat”
- “spread invasive species”
- “protecting vegetation and wildlife habitat”
- “wildlife habitat”
Forest Management Wildfire
- “Wildfire risk does not justify eliminating roadless protections”
- “increase opportunities for human-caused wildfire ignition”
- “distinguish between targeted fuels treatment needed to protect communities and infrastructure and substantially broader road construction”
- “existing Roadless Rule already allows appropriate management actions”

What it names

National Forests: Ashley National Forest

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeEA analysisAnalytical gapEvidenceRequestAlternative

I am submitting these comments regarding the effect that rescission of the 2001 Roadless Rule could have on the Ashley National Forest, Flaming Gorge National Recreation Area, Manila, Utah, and Daggett County. I request that USDA retain the protections of the 2001 Roadless Rule, or at minimum maintain equivalent or greater protections for inventoried roadless areas in and around Daggett County and Flaming Gorge National Recreation Area. I spend significant time in and around Manila and Flaming Gorge and have personally observed that the undeveloped character of the surrounding National Forest is one of the area's defining qualities. Visitors come here for Flaming Gorge, fishing, hunting, wildlife, camping, hiking, scenery, and access to relatively undeveloped public lands. For a small rural community like Manila, these scenic and recreational resources are economic infrastructure. Their long-term value should be weighed against any projected short-term benefit from additional timber, mineral, development, or road access. The lands surrounding Manila and Flaming Gorge derive substantial value because large portions remain undeveloped, scenic, intact, and connected. Forest Service planning documents recognize approximately 119,511 acres of inventoried roadless areas within Flaming Gorge National Recreation Area and recognize the area's scenery and recreation as important drivers of tourism and the local economy. Roadless areas of particular concern include Sheep Creek West, Sheep Creek East, Hideout Draw, Bare Top, Mt. Lena, Little Hole, Roadshed, North Slope, Goslin, and Grizzly Ridge. USDA should evaluate the cumulative effects of losing roadless protections across these adjoining areas rather than considering future roads only one project at a time. Roads can fragment wildlife habitat, increase erosion and sedimentation, spread invasive species, change recreation patterns, increase opportunities for human-caused wildfire ignition, and permanently alter scenic and undeveloped landscapes. This is particularly important around Flaming Gorge Reservoir, Sheep Creek, Carter Creek, Goslin Creek, and their tributaries. Protecting intact watersheds should remain an important preventative management tool for maintaining water quality, reducing erosion, and protecting vegetation and wildlife habitat. Wildfire risk does not justify eliminating roadless protections. The existing Roadless Rule already allows appropriate management actions, including certain vegetation treatments and exceptions addressing imminent threats involving wildfire, flooding, public health, and safety. USDA should distinguish between targeted fuels treatment needed to protect communities and infrastructure and substantially broader road construction, reconstruction, timber access, or development. Those are very different management decisions. Greater road access can also increase human-caused wildfire ignition and reduce the quiet, remote recreational character that makes these lands valuable. Around Manila, recreation associated with Flaming Gorge, the Green River, hunting, fishing, wildlife viewing, camping, hiking, and scenic landscapes is an important part of both the community's identity and economy. Permanent fragmentation could exchange a long-term renewable recreation asset for short-term development benefits. The economics of new roads should also be fully considered. The Forest Service already faces substantial deferred maintenance needs for existing roads and infrastructure. Before allowing additional roads USDA should evaluate who will pay to construct, maintain, repair, and ultimately decommission them. Roadless protection should also not be confused with Wilderness designation. Disagreement over formal Wilderness designation should therefore not be used as justification for eliminating roadless protections. If USDA determines that additional local flexibility is necessary, a better approach would be to retain roadless protections while allowing narrowly tailored exceptions. At minimum, I request that USDA retain existing protections for roadless areas surrounding Manila, Flaming Gorge Reservoir, Sheep Creek, Bare Top, Hideout Draw, Mt. Lena, Little Hole, Roadshed, North Slope, Goslin, and Grizzly Ridge unless a location-specific analysis demonstrates that removing those protections would provide benefits exceeding the long-term costs to scenery, recreation, wildlife habitat, watershed integrity, wildfire risk, road maintenance, and Daggett County's recreation-based economy. Once these landscapes are fragmented by permanent roads, their roadless character is difficult or impossible to restore. That irreversibility warrants continued protection. I request that USDA retain the 2001 Roadless Rule or establish equivalent or heightened protections for the Ashley National Forest and Flaming Gorge National Recreation Area in Daggett County, Utah.