Comment Analysis · Docket FS-2025-0001

FS-2025-0001-573396

Opposes rescissionA1 strongSubstance 14/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment establishes that the DEIS fails to provide evidence that rescission reduces fire severity or identifies specific blocked projects, while documenting the commenter's direct reliance on specific Utah canyons for recreation and habitat, and requesting the No Action alternative or targeted state-specific rulemaking.

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

A1 strong: Must be answered — it names the law.

Owed an answer on Analytical gap, Alternative, Legal.

Standard dismissals it defeats

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.
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.
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.

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.
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.

Topics

Environmental Protection Biodiversity
- “fragment habitat”
- “wildlife habitat, native plants”
- “protect intact backcountry, habitat”
Water Quality Quantity
- “clean air and water”
- “sediment into the streams that supply the Wasatch Front”
- “watershed worth protecting”
Recreation Tourism Public Use
- “backcountry ski, hike, and mountain bike”
- “erase the backcountry character”
- “uncertainty for recreation”
Forest Management Wildfire
- “wildfire rationale is unsupported”
- “wildfires are nearly four times more likely to start near roads”
- “targeted wildland-urban interface fuel reduction”

What it names

National Forests: Wasatch-Cache National Forest
Law cited: 36 CFR Part 294

The comment

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

Comment on Proposed Rule: Special Areas; Roadless Area Conservation (Rescission of the 2001 Roadless Rule) Docket FS-2025-0001 | RIN 0596-AD66 | 91 FR 53827 1. Introduction I am Brad Allenick, a resident of Summit Park, Utah, on the edge of open space and near the Uinta-Wasatch-Cache National Forest. I backcountry ski, hike, and mountain bike on these lands year-round. Cardiff Fork, Days Fork, Silver Fork, and upper Big Cottonwood Canyon have given me some of the best backcountry runs of my life. Lambs Canyon, which is contiguous with the open space behind my home, is where I ski, hike, and ride most often. I depend on these lands for wildlife habitat, native plants, and clean air and water. I oppose full rescission and urge the Department to select the No Action alternative. 2. Background I am commenting on the proposed rescission of 36 CFR Part 294, Subpart B, which restricts road construction, road reconstruction, and timber harvest in inventoried roadless areas, and on the accompanying Draft Environmental Impact Statement (DEIS). The proposal would remove the national prohibition on roughly 44.7 million acres, including about four million acres in Utah, and leave these decisions to individual forest plans. 3. Analysis Impact. The Wasatch is among the most heavily used mountain landscapes in the West, and its unroaded canyons are what make the experience and the watershed worth protecting. New roads and logging would fragment habitat, erode slopes, put sediment into the streams that supply the Wasatch Front, and erase the backcountry character that draws people here. The wildfire rationale is unsupported. The DEIS itself acknowledges that ignitions and burned acres are substantially lower in roadless areas. Its conclusion that roads would improve suppression rests on longer containment times, with no evidence that rescission would reduce fire severity or protect communities. Reporting on a peer-reviewed study from this year indicates wildfires are nearly four times more likely to start near roads than in roadless areas [verify citation before filing]. The 2001 rule also already allows fuel reduction and fire suppression. The DEIS does not identify specific projects that were blocked and could not proceed under those exceptions. Unconsidered consequences. The Forest Service has a large deferred maintenance backlog on its existing roads. New roads it cannot maintain mean more erosion, closures, and cost. Replacing a uniform national floor with forest-by-forest decisions also creates uncertainty for recreation and habitat protection. Process. The proposal, DEIS, and cost-benefit analysis were released together with a short comment period for a decision affecting tens of millions of acres. The 2025 scoping period drew roughly 626,000 comments, with about 99 percent reportedly opposed. The final rule should show how that record was weighed. Information requested: specific projects blocked by the rule that its exceptions would not allow; Utah-specific estimates of road construction and harvest in the Uinta-Wasatch-Cache; how new roads will be funded given the maintenance backlog; and evidence that new roads reduce fire severity. 4. Recommendations Select the No Action alternative. If fire management is the concern, adopt narrow, targeted authorities for wildland-urban interface fuel reduction rather than rescinding protections across 44.7 million acres. If Utah seeks flexibility, use a state-specific rulemaking with full public process, as in Colorado and Idaho. Issue a revised DEIS with state- and forest-level impact estimates and a full comment period, and hold public meetings in Utah. 5. Conclusion The Roadless Rule has protected intact backcountry, habitat, and watersheds for 25 years, and the agency's own analysis does not show repeal would reduce wildfire risk. I ask the Department to (1) select No Action; (2) use targeted wildland-urban interface fire authorities if needed; (3) pursue any Utah-specific changes through a state rulemaking; and (4) issue a revised DEIS with a full comment period and public meetings. Respectfully, Brad Allenick Summit Park, Utah