Comment Analysis · Docket FS-2025-0001

FS-2025-0001-594895

Opposes rescissionA2 moderateSubstance 13/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment documents that the agency's proposal to rescind the Roadless Rule fails to reconcile its wildfire management rationale with DEIS Table 21 data showing higher fire density on roaded lands, does not address prior legal deficiencies in local-rule approaches, improperly requests comment on out-of-scope plan amendments, and fails to quantify carbon storage impacts or account for water quality pressures in Utah's roadless watersheds.

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

  • Environmental Protection Biodiversity
    • “displace wildlife and wreck havoc on the immediate ecosystem”
    • “logging harm streams, decrease fish”
    • “preserve roadless values”
  • Forest Management Wildfire
    • “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
    • “reconcile this proposal with the ignition data in DEIS Table 21”
    • “fire density on roaded land than inside the affected roadless areas”
  • Water Quality Quantity
    • “1,466 municipal water intakes sit in watersheds containing affected roadless areas”
    • “Opening these watersheds to roads and timber operations adds pressure”
    • “Colorado River allocation debate is already putting water in this region at serious risk”
  • Climate Carbon Storage
    • “inventoried roadless areas contain about 5 percent of the stored forest carbon”
    • “quantify the change in carbon storage and sequestration”
    • “roughly 0.9 billion metric tons”

What it names

National Forests
Dixie National Forest
Roadless areas
Bear Valley PeakBunker CreekLava BedsMineral CanyonTimbered Cinder Cone

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 My family owns a cabin that backs up to the Dixie National Forest in Utah. That is not an abstraction. The Lava Beds roadless area, all 14,944 acres of it, is part of the landscape I grew up on. I hiked on it, around it, beneath it, and looked down from it as a child. I lost my brother to a hiking accident in Snow Canyon State Park. These are not distant federal lands to me. They are the ground my family stands on. I oppose the rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001. The Dixie National Forest holds roadless areas including Timbered Cinder Cone, Hancock, Mineral Canyon, Bunker Creek, Bear Valley Peak, and Lava Beds, among others. Utah holds 222 inventoried roadless areas totaling 4,013,529 acres. I have watched what happens when land management is hurried and careless. I have seen logging harm streams, decrease fish, and change the landscape in ways that do not reverse. I have seen poor management during and after roadwork displace wildlife and wreck havoc on the immediate ecosystem. Those observations are not ideology. They are what I have seen with my own eyes in country I know personally. The agency's own record makes a finding about fire that directly contradicts the reasoning behind this proposal. The DEIS 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." If the agency is rescinding protection of roadless areas partly on wildfire management grounds, it must explain why it is departing from that finding. I ask that the agency reconcile this proposal with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas, and explain that departure in plain terms. The state-by-state approach this proposal leans on has been tried before. The agency's own record acknowledges that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." That rejection led to litigation the agency lost. The Ninth Circuit identified deficiencies in the local-rule approach. The agency has not explained how this proposal avoids repeating those same deficiencies, and it has not addressed its own prior finding that local decision-making can incrementally erode nationally significant roadless values. The agency should answer that question directly before this proposal advances. The proposal also asks the public to comment on something the agency simultaneously declares out of scope. The record reflects: "The proposed rule concedes that subsequent land management plan amendments and revisions 'could increase the area where timber harvest and road construction would be allowed,' declares changes to plans beyond the scope of the proposal, and then requests public comment on them (91 FR 53830)." That is not a fair comment process. The foreseeable plan-amendment scenario, including expanded timber harvest area across places like the Dixie National Forest roadless units I named, must be analyzed as part of this action, not deferred to future proceedings the public cannot yet see or contest. On carbon, the agency identified a significant number and then declined to follow it through. "The DEIS cites the estimate that these inventoried roadless areas contain about 5 percent of the stored forest carbon in the coterminous United States, roughly 0.9 billion metric tons." The DEIS reaches no conclusion about what roading and harvest would do to that figure. I ask that the agency quantify the change in carbon storage and sequestration under each alternative before it finalizes anything. Across the Intermountain region, which includes Utah, 1,466 municipal water intakes sit in watersheds containing affected roadless areas. The Colorado River allocation debate is already putting water in this region at serious risk. Opening these watersheds to roads and timber operations adds pressure that is not accounted for in this proposal. The agency is responsible for the conservation and protection of the land and resources that made this country what it is. My children have the right to live on this land as it is. We have plenty of roads and developed areas already. Without these protections, that will be the only thing left. The agency should answer each of the points raised here in the record before any final action is taken. Sincerely, Rebecca Shillander Utah

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