Comment Analysis · Docket FS-2025-0001

FS-2025-0001-562916

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

In short: The comment documents specific reliance interests in six named Utah roadless areas, cites DEIS Table 21 data showing higher ignition densities on roaded lands, and identifies gaps in the agency's analysis regarding wildfire risk, reliance interests, small entity impacts, and downstream water quality safeguards.

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
- “I hike and camp all throughout the wilderness here”
- “The Roadless Area Conservation Rule is the legal backbone that makes these experiences possible”
- “Opening more roads does not serve recreation or quiet”
- “The Big Horseshoe trail is absolutely gorgeous and needs to be preserved”
Forest Management Wildfire
- “The connection between road access and fire risk is not speculative”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “quantify the expected increase in human-caused ignitions from new road access”
- “weigh that increase honestly against any claimed reduction in wildfire hazard”
Water Quality Quantity
- “1,466 municipal water intakes sit in watersheds containing affected roadless areas”
- “Road construction disturbs soil and increases sedimentation”
- “the rescission creates no substitute protection”
- “downstream water quality will be adequately safeguarded”
Legal Regulatory Framework
- “Under established administrative law, an agency changing course must identify and genuinely assess the reliance interests”
- “The regulatory flexibility analysis reaches its no-significant-impact conclusion by spreading losses”
- “A certification of no significant impact on small entities cannot survive that contradiction”
- “The agency should withdraw that certification and replace it with an analysis focused on the small entities”

What it names

National Forests: Fishlake National Forest Uinta National Forest
Roadless areas: Big BaldyBig HorseshoeLevan PeakOak Creek

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The roadless areas of Utah are not abstractions to me. I hike and camp all throughout the wilderness here, and I hold a deep conviction that the natural life in these places deserves to remain undisturbed and quiet. I paddle in Fish Lake, Manti, the Uintah national forest including Heber, and many more. I ride trails all throughout the Uinta National Forest, especially near Payson Canyon. The Roadless Area Conservation Rule is the legal backbone that makes these experiences possible, and the proposal to rescind it, Docket FS-2025-0001, would do irreversible harm to places I know and care about. The North Peak roadless area in the Uinta National Forest covers 15,673 acres, and I camp there multiple weeks throughout the year. I have watched that area carry the scars of wildfire, and the connection between road access and fire risk is not speculative. The agency's own 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 DEIS reinforces this with ignition data: "Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads." Given that the proposal justifies rescission partly on wildfire and fuels management grounds, I ask that the agency explain why it departs from these prior findings, and that it quantify the expected increase in human-caused ignitions from new road access and weigh that increase honestly against any claimed reduction in wildfire hazard. The Haystack Hill roadless area, 6,255 acres in the Uinta National Forest, is a place I return to many times throughout the year. The canyon is already heavily traveled along the roads that exist. Opening more roads does not serve recreation or quiet; it opens the door to extraction that degrades the landscape. That concern extends across all six of the inventoried roadless areas I am writing about: Levan Peak at 22,092 acres in the Manti-La Sal National Forest, Sanpitch at 29,129 acres in the Manti-La Sal, Oak Creek at 54,053 acres in the Fishlake National Forest, and Big Horseshoe at 17,557 acres in the Manti-La Sal. Hiking Big Baldy in the Sanpitch area was an important part of my experience growing up, and the current rule is what I have relied on to know that area would be maintained. Camping near Oak Creek, the quiet of it, matters to me. The Big Horseshoe trail is absolutely gorgeous and needs to be preserved. Utah holds 222 inventoried roadless areas totaling 4,013,529 acres, and the rescission places all of it at risk from decisions made area by area without the structural protection the rule provides. 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. That omission is not a procedural nicety. Under established administrative law, an agency changing course must identify and genuinely assess the reliance interests its prior policy created. This comment is one such interest. The agency must identify and weigh the reliance interests described in the comments it receives, including mine, before it proceeds further. The regulatory flexibility analysis reaches its no-significant-impact conclusion by spreading losses across every small firm in the sector nationally, rather than examining the outfitters, guides, and tour operators who actually hold permits in the affected areas. The DEIS names those operators as affected parties, and the agency's own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million per year. A certification of no significant impact on small entities cannot survive that contradiction. The agency should withdraw that certification and replace it with an analysis focused on the small entities actually operating in these roadless areas, not a national average that dilutes the real harm. The Manti-La Sal and Uinta watersheds that sustain these places are not isolated from communities downstream. Across the Intermountain region, which includes Utah, 1,466 municipal water intakes sit in watersheds containing affected roadless areas. Road construction disturbs soil and increases sedimentation in ways that the current rule was designed to prevent, and the rescission creates no substitute protection. The agency has not demonstrated that downstream water quality will be adequately safeguarded, and it should be required to say plainly how it will be. Sincerely, Nathan Jones Spanish Fork, Utah