Comment Analysis · Docket FS-2025-0001

FS-2025-0001-587229

Opposes rescissionA1 strongSubstance 11/24Owed an answerPosted October 6, 2026 On Regulations.gov

Small family — One letter sent by 3 to 9 people, copied or lightly reworded. One of 4 submissions in its group. See the letter, its submissions and topics.

Carries the letter's score — A copy of a family's letter; it holds the score and answerability level of the letter it sent.

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. This rating is the one its shared letter earned.

Owed an answer on 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
- “backcountry hunting”
- “hunting and shooting sports industry”
- “world-class pursuits”
- “sustainable recreation economy”
Wildlife Habitat
- “summer range, security cover, and migration corridors”
- “trophy elk and mule deer”
- “fragment habitat”
- “high-value big game habitat”
Water Quality Quantity
- “primary headwaters for our local communities”
- “sustain sensitive cold-water trout fisheries”
- “chronic sediment runoff”
- “compromises water quality downstream”
Economic Impact Fiscal
- “total economic output and retail impact”
- “annual sawtimber harvest increase”
- “infrastructure maintenance liabilities”
- “deferred maintenance backlog”

What it names

National Forests: Ashley National Forest
Roadless areas: Dry Fork

The comment

As a backpacker, angler, and fiscally conservative resident of Vernal, Utah, I urge the U.S. Forest Service to adopt Alternative 1 (No Action) and retain the 2001 Roadless Area Conservation Rule. Living in the Uinta Basin, my backyard is the Ashley National Forest. I regularly pack into the backcountry, and fish across the unroaded drainages of the Uinta's. While the congressionally designated High Uinta's Wilderness protects the high alpine core, it is the surrounding Inventoried Roadless Areas (IRAs)-including the Whiterocks, Dry Fork, and Lake Mountain roadless blocks-that make these world-class pursuits possible. Outdoorsman like me do not want to drive a truck on every ridge. Packing in on horseback or hiking miles with a rifle and pack frame is the essence of backcountry hunting. That experience of grit, self-reliance, and solitude is central to our American heritage, and it requires large, unspoiled terrain without motorized disruption. Maintaining large, undeveloped blocks of public land is essential for wildlife and watershed health. Roadless terrain provides crucial summer range, security cover, and migration corridors for Utah's trophy elk and mule deer. Roads fragment habitat and push herds onto private lands, degrading hunting quality for everyone. The roadless drainages of the Uinta's serve as the primary headwaters for our local communities and sustain sensitive cold-water trout fisheries. Industrial roadbuilding leads to chronic sediment runoff that ruins spawning gravels and compromises water quality downstream. From a fiscal and economic standpoint, repealing the Roadless Rule is fundamentally flawed: According to national industry analyses, the total economic output and retail impact of the hunting and shooting sports industry exceeds $107 billion to $133 billion, supporting hundreds of thousands of jobs. With direct retail sales and economic generation around $45.2 billion—a figure higher than the individual annual GDP of roughly 121 countries-hunting is a proven, sustainable driver of real economic activity. In Utah, hunters pour money directly into local gateway communities like Vernal, buying fuel, groceries, sporting goods, lodging, and outfitting services season after season. In sharp contrast, the Forest Service's own estimates project an annual sawtimber harvest increase of just $5.2 to $11.4 million in revenue to the Treasury/USFS, and $4.6 to $10.6 million to the timber industry if the rule were rescinded. Jeopardizing high-value big game habitat that anchors a multi-billion-dollar sustainable recreation economy for a fraction of a percent in timber receipts makes zero business sense. Then there is the problem of increasing infrastructure maintenance liabilities. The Forest Service already manages roughly 370,000 miles of existing roads and faces an estimated $10.8 billion deferred maintenance backlog, with roughly 55% tied to roads alone. Building new road networks into pristine backcountry creates permanent maintenance obligations while diverting scarce funds from the decaying infrastructure the agency already cannot afford to maintain. Intact roadless areas are not economically "idle"—they are natural infrastructure powering a multi-billion-dollar hunting economy, sustaining clean drinking water, and sparing taxpayers from compounding infrastructure liabilities. I respectfully urge the Forest Service to protect these investments, adopt the No Action alternative, and keep the 2001 Roadless Rule in place. Best wishes, warm regards, and high esteem, Robert G Hatch