Comment Analysis · Docket FS-2025-0001

FS-2025-0001-605528

Opposes rescissionA0 noneSubstance 11/24Posted October 7, 2026 On Regulations.gov

In short: The comment establishes that the DEIS failed to provide site-specific analysis for the Tongass, Wasatch, and Uinta National Forests, and documents that the agency's own data (DEIS Table 21) shows a 7.5x increase in human-caused ignitions near roads, while the economic analysis reveals a $6.9 billion deferred maintenance backlog and a negative net present value of $92 million.

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

A0 none: Counted, not answered.

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

Environmental Protection Biodiversity
- “jeopardizes 9.3 million acres of the world's largest remaining temperate rainforest”
- “driving the endemic Alexander Archipelago wolf closer to extinction”
- “destroying the exact wild characteristics that millions of Utahns rely on for outdoor recreation and ecological stability”
Water Quality Quantity
- “degrade world-class salmon spawning habitats through toxic road runoff and massive sedimentation”
- “protect steep, fragile mountain watersheds”
- “harm water quality”
Legal Regulatory Framework
- “legally deficient under the National Environmental Policy Act (NEPA)”
- “Failure to Analyze Site-Specific Consequences”
- “elimination of every single conservation-oriented alternative”
Forest Management Wildfire
- “human-caused ignitions increase in abundance with proximity to roads”
- “increasing road access will increase the overall number and frequency of wildfires”
- “directly endangering nearby rural communities and over-allocating strained fire suppression resources”

What it names

National Forests: Tongass National Forest Uinta National Forest

The comment

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

I am writing to express my strong opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule. I am a resident of Utah living near and regularly recreating in the Wasatch National Forest and the Uinta National Forest. I also deeply care about the ecological impacts of this rule, specifically in the Tongass National Forest in Alaska. The DEIS removes protections from every one of these landscapes without analyzing the site-specific consequences for any of them. As a regular user of Utah’s public lands and a citizen invested in our nation's foundational ecological treasures, I am providing this comment as record evidence that localized, site-specific analysis was owed and legally deficient under the National Environmental Policy Act (NEPA). I urge the agency to reject the proposed action based on the following critical flaws: 1. Failure to Analyze Site-Specific Consequences (Tongass, Wasatch, and Uinta National Forests) The DEIS completely fails this standard across my most cherished distinct ecosystems: The Tongass National Forest: Removing the Roadless Rule jeopardizes 9.3 million acres of the world’s largest remaining temperate rainforest, opening it to aggressive road building and industrial logging. This action directly targets rare, ancient old-growth Sitka spruce stands for clearcutting. Building roads here will degrade world-class salmon spawning habitats through toxic road runoff and massive sedimentation, while driving the endemic Alexander Archipelago wolf closer to extinction. The Wasatch and Uinta National Forests: In my home state of Utah, these forests protect steep, fragile mountain watersheds. Stripping roadless protections here opens vulnerable backcountry slopes to localized fragmentation, destroying the exact wild characteristics that millions of Utahns rely on for outdoor recreation and ecological stability. 2. Pretextual Purpose and Need The stated purpose and need for this action is fundamentally flawed. It is explicitly framed around reducing regulatory burdens and returning decision-making to local officials—not forest health or wildfire mitigation. The agency’s bias is laid bare by its elimination of every single conservation-oriented alternative. The DEIS openly admits that preserving more acreage "would not be responsive to the deregulatory executive orders," and goes so far as to eliminate a viable option simply because analyzing roadless values presents "an administrative and legal burden for the agency." Furthermore, the agency’s own words expose that this rule change offers no proactive stewardship, stating: "This proposed rescission does not mandate timber cutting or road construction." No management benefits or health outcomes are promised; the agency is merely stripping a foundational environmental protection to satisfy an administrative checklist. 3. Proximity of Roads Linearly Correlates to Increased Wildfire Risk (DEIS Table 21) The agency’s own data from 2014 to 2024 completely refutes any narrative that road building aids fire management. Human-caused ignitions run at 22.4 per million acres per year on national forest land, compared to a mere 3.0 ignitions inside protected roadless areas—a 7.5x increase where roads exist. The DEIS rightly concludes that "human-caused ignitions increase in abundance with proximity to roads." The effects analysis clearly concedes that increasing road access will increase the overall number and frequency of wildfires, directly endangering nearby rural communities and over-allocating strained fire suppression resources. This is an unacceptable liability for communities flanking the Wasatch and Uinta fronts. 4. Severe Economic Deficit and Infrastructure Backlog (DEIS Economics & Infrastructure Analysis) The Forest Service cannot safely maintain the infrastructure it already owns. Regular road appropriations collapsed from 234 million in 2004 to just $73 million in 2024, leaving the agency with a staggering 6.9 billion deferred maintenance backlog. The agency’s own Cost-Benefit Analysis shows that the math cannot clear zero. The agency's accounting concludes that the total net present value of this action runs as low as negative 92 million. The DEIS openly admits that overall road mileage, deferred maintenance, and long-term management costs are all likely to increase under this proposal. It is fiscally irresponsible to build new, high-liability roads while drowning in billions of dollars of unaddressed maintenance on existing routes. Because the Forest Service has failed to analyze the localized, site-specific destruction that logging roads would bring to the backcountry areas of the Tongass, Wasatch, and Uinta National Forests, and because its own internal data shows this action will increase fire risks, harm water quality, and worsen a multi-billion-dollar infrastructure deficit, I strongly oppose the rescission. The agency must maintain full, nationwide protections under the 2001 Roadless Rule.