Comment Analysis · Docket FS-2025-0001

FS-2025-0001-601400

Opposes rescissionA3 weakSubstance 8/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents that the proposed rescission of the 2001 Roadless Rule lacks sufficient data on wildfire suppression, fails to quantify impacts on water and recreation, and utilizes an inadequate public comment process, thereby urging the agency to select the no-action alternative and extend the comment period.

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

A3 weak: Substantive, but easier to set aside.

Owed an answer on Analytical gap.

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.
Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
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.
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.

Topics

Water Quality Quantity
- “Wasatch Front communities rely on national forest watersheds for drinking water”
- “quantify harm to municipal water supplies”
- “erosion”
Wildlife Habitat
- “Roadless areas also provide big-game and native trout habitat”
- “spread invasive species”
- “protect wildlife habitat”
Recreation Tourism Public Use
- “dispersed recreation”
- “backcountry that sustains Utah's outdoor economy”
- “recreation revenue”
Governance Policy Process
- “process is inadequate”
- “short comment window”
- “hold public hearings in the affected states”

The comment

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

I am a resident of Utah, and I strongly oppose the proposed rescission of the 2001 Roadless Rule. I urge the Department to select the no-action alternative and keep the rule in place. 1. The rule works, and the public supports it. The 2001 Rule has protected undeveloped national forest land for 25 years, and the public supported it through extensive comment and hearings. Rescinding it removes a durable, nationwide protection. Each forest plan could then be revised more easily, with less public attention, to allow roads and logging. 2. The wildfire rationale is weak. The proposal says the rule limits wildfire suppression and active management. The rule already contains exceptions for road building related to public safety, and it has never prevented firefighting. Most fire ignitions and home losses occur near communities, not in remote roadless interiors. The Department should show data for any claim that the rule has blocked suppression, and it should weigh that against the evidence that new roads increase human-caused ignitions and spread invasive species. 3. Roads are a long-term liability. The forest Service already has a maintenance backlog on its existing road network. Building new roads in steep, remote terrain adds costs that taxpayers carry long after any timber sale ends. The draft EIS should present full lifecycle road costs, including maintenance, erosion, and decommissioning. 4. Utah's watersheds, wildlife, and economy depend on roadless land. Wasatch Front communities rely on national forest watersheds for drinking water. Roadless areas also provide big-game and native trout habitat, dispersed recreation, and the backcountry that sustains Utah's outdoor economy. The analysis should quantify harm to municipal water supplies and recreation revenue. 5. The rescission removes a safeguard against disposal and development. Utah's congressional delegation has openly advocated selling federal lands. Rescinding the Roadless Rule would strip protections from land that could later be targeted for sale or intensive development. Land with an existing road network is more likely to be developed, and roads would make it easier to justify transferring this land out of public hands. The Department should explain what it would do to ensure that rescission does not enable disposal. 6. The process is inadequate. Rescinding protections on roughly 45 million acres through a short comment window, with an extension of only 15 days does not allow meaningful public review of a draft EIS this large. The Department should extend the comment period and hold public hearings in the affected states, including Utah.