Comment Analysis · Docket FS-2025-0001

FS-2025-0001-577034

Opposes rescissionA1 strongSubstance 17/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment establishes that the agency's proposal to rescind the Roadless Area Conservation Rule fails to reconcile its wildfire justification with its own data showing higher ignition rates on roaded lands, fails to quantify administrative burdens not covered by existing exceptions, and relies on a flawed small-business certification that obscures specific economic harms to outfitters and guides in Utah.

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, Evidence, 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

Recreation Tourism Public Use
- “Secluded natural areas are where I go to camp, to find the calm”
- “I want them to adventure and make memories with our family away from cultivated society”
- “The proposal before the agency threatens that directly”
- “recreation losses at a minimum of $6.1 million a year”
Water Quality Quantity
- “its preservation protects our watershed, and that matters to the communities downstream”
- “1,466 municipal water intakes sit in watersheds containing affected roadless areas”
- “These are not abstract figures. They describe a water supply that the rule protects”
- “rescission would put at risk”
Forest Management Wildfire
- “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”
- “The proposal does not explain how rescission improves fire outcomes”
- “reconcile the rescission with the ignition data in its own DEIS Table 21”
Economic Impact Fiscal
- “Our public land should not be used for temporary gains or commercial profit”
- “revenue projected at $5.2 to $11.4 million a year in timber receipts”
- “existing road system already carries a $6.9 billion maintenance backlog”
- “explain how expanding a road network it cannot afford to maintain serves the public interest”

What it names

National Forests: Wasatch-Cache National Forest
Roadless areas: Twin Peaks
Law cited: 36 C.F.R. Section 294.12

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 Secluded natural areas are where I go to camp, to find the calm that lets me work harder when I return home and be a more motivated member of my community. That is not a luxury. It is part of how I function, and I want my kids to have the same. They should have access to just as many public lands as I do, because it inspires us to see the world as it once was and to continue that beauty in our lives and relationships. I want them to adventure and make memories with our family away from cultivated society and its ills. The proposal before the agency threatens that directly, and the agency's own record does not support it. The strongest objection in that record concerns fire. I hike Twin Peaks, a 6,157-acre inventoried roadless area in Wasatch-Cache National Forest in Utah, regularly. It is close to my home, it has meant the world to me as a place to recharge, and I have been going for a decade with friends and family. I intend to bring my kids. The agency now justifies opening areas like this to road building in part on wildfire and fuels management grounds. Its own prior findings say the opposite: "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 proposal does not explain how rescission improves fire outcomes when the agency's own data show roaded land carries far greater ignition density than inventoried roadless areas. I ask that the agency explain why the proposal departs from those prior findings and reconcile the rescission with the ignition data in its own DEIS Table 21. I also fish and hike the High Uintas Wilderness, 1,394,000 acres in Utah. I have been going for three years. Beyond the recreation, I understand that its preservation protects our watershed, and that matters to the communities downstream. Across the Intermountain region, which includes Utah, 1,466 municipal water intakes sit in watersheds containing affected roadless areas. Utah holds 222 inventoried roadless areas totaling 4,013,529 acres. These are not abstract figures. They describe a water supply that the rule protects and that rescission would put at risk. Our public land should not be used for temporary gains or commercial profit, and I cannot see how the numbers here justify the trade. The agency's own analysis 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 revenue projected at $5.2 to $11.4 million a year in timber receipts, the record books recreation losses at a minimum of $6.1 million a year and a net present value that cannot establish a net benefit, all while the existing road system already carries a $6.9 billion maintenance backlog. The agency must reconcile those figures on the record and explain how expanding a road network it cannot afford to maintain serves the public interest. The proposal also claims administrative burden as a justification, but the rule already contains exceptions. It "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." Before rescinding a rule that took more than 600 public meetings and 1.6 million comments to write, the agency should be able to name which specific burdens are not addressed by those existing exceptions, and quantify them. It has not done so. Finally, the small-business certification attached to this proposal does not survive contact with the analysis beside it. "The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year." That certification was reached by spreading losses across the national average firm rather than examining the outfitters and guides who actually hold permits in the affected areas. The agency should withdraw the certification and conduct an assessment focused on the businesses that will actually feel the loss, not a diluted national average that obscures the real harm. Public land should be managed for future generations and for the preservation of American beauty and not for temporary commercial gain. I oppose this rescission and ask that the agency address each of the points above before taking any final action. Sincerely, Anonymous Western USA