Comment Analysis · Docket FS-2025-0001

FS-2025-0001-224584

Opposes rescissionA1 strongSubstance 14/24Owed an answerPosted August 20, 2026 On Regulations.gov

In short: The comment establishes that the DEIS fails to model ignition density for the 18.2 million acres of new roads, ignores the agency's own research (PNW-GTR-509, RMRS-GTR-42-vol.6) regarding sediment and fragmentation, and fails to analyze the reasonably foreseeable amendments enabled by rescission, thereby documenting a significant gap in the analysis of wildfire and environmental impacts.

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

Forest Management Wildfire
- “The DEIS fails to demonstrate a net wildfire benefit”
- “roads into backcountry terrain do not stop fires, they introduce what starts them”
- “The Final EIS must model ignition density under both alternatives”
- “Calkin et al. (2023)... concluded that wildland urban fire disasters are not a wildfire problem”
Governance Policy Process
- “The DEIS never explains why that mechanism is inadequate”
- “Amendments enabled by rescission are reasonably foreseeable and must be analyzed, not deferred”
- “The agency must reconcile this proposal with the science it produces, and has not”
- “The Forest Service must adopt the No Action Alternative”
Recreation Tourism Public Use
- “I have organized my recreation around the roadless system for years”
- “roadlessness delivers a low density, self reliant experience roaded lands cannot”
- “The $6.1 million annual recreation loss figure obscures a class of experience no amendment restores”
Water Quality Quantity
- “documents sediment production, hydrologic alteration”
- “post fire sedimentation costs to a Front Range municipal supply”

What it names

Roadless areas: Rocky Mountain
Law cited: 5 U.S.C. 553
Works cited: 10.1038/s41598-022-06002-310.1071/wf1315810.1073/pnas.231579712010.3390/f7100237

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapEvidenceLegal

I am an outdoor recreationist who frequently uses the Arapaho and Roosevelt National Forests. Every source I cite is federally funded and most is USDA Forest Service research. The agency must reconcile this proposal with the science it produces, and has not. I recognize the rule removes only Subpart B and that Subparts C and D remain in effect. That is itself strong evidence against the Purpose and Need. Colorado and Idaho show that place based tailoring is already available inside the roadless framework, through the 5 U.S.C. 553(e) petition process the preamble itself points to. The DEIS never explains why that mechanism is inadequate, nor why the alternative to a national rule is no rule rather than more state rules. That alternative must be analyzed. The Forest Service is publishing the California Southern Zone Human Caused Fire Ignition Analysis, mapping 26 years of ignitions across four national forests and 850 miles of roads. It finds roughly two thirds of human caused fires start along roadsides, and the agency is using it to prioritize treatment along existing roads. It cannot rely on that operationally while ignoring it when proposing new roads. Downing et al. (2022), with Rocky Mountain Research Station coauthors, found most cross boundary fires start on private land, and that on national forests road density was the strongest predictor of ignitions. My father spent 20 years with the Forest Service. Field staff have long understood that roads into backcountry terrain do not stop fires, they introduce what starts them. The DEIS anticipates permanent roads across 18.2 million acres and temporary roads across 11.3 million acres and converts neither into expected ignitions, though it maintains the FPA-FOD and InFORM databases and its own roads and IRA layers. The Final EIS must model ignition density under both alternatives. The 9.8 million acre WUI overlap figure is undifferentiated by distance from structures. Cohen (2000), written at the agency's Missoula Fire Sciences Laboratory, established that structural survival depends on conditions within 30 to 60 meters of the home, a finding USGS work (Syphard 2014) later confirmed empirically. Calkin et al. (2023), led by Forest Service researchers, concluded that wildland urban fire disasters are not a wildfire problem and that agencies managing wildland fuels have limited impact on community destruction. The Final EIS must report what fraction of the 9.8 million acres lies within 30 to 60 meters of habitable structures, and what fraction is untreatable solely because of Subpart B. Barnett et al. (2016) found only a 6.8 percent encounter rate between federal treatments and later wildfire. PNW-GTR-509, the agency's own roads synthesis produced alongside the 2001 rule, documents sediment production, hydrologic alteration, invasive spread, and passive use value loss. RMRS-GTR-42-vol.6 documents the grass fire cycle, PNW-GTR-846 landscape scale fragmentation, and RMRS-GTR-114 post fire sedimentation costs to a Front Range municipal supply. The DEIS engages none of these and never says which of its own findings the agency now believes wrong. The DEIS bounds its impacts with existing plan direction, concedes that later amendments could expand harvest and roads beyond those impacts, then declares amendments out of scope while requesting comment on them. Amendments enabled by rescission are reasonably foreseeable and must be analyzed, not deferred. The economics have the same defect: the preamble concedes a $6.9 billion road maintenance backlog without disclosing the added liability from 18.2 million newly available acres. The preamble invites comment on these. I have organized my recreation around the roadless system for years because roadlessness delivers a low density, self reliant experience roaded lands cannot. The $6.1 million annual recreation loss figure obscures a class of experience no amendment restores once a road is built. The DEIS fails to demonstrate a net wildfire benefit and fails to analyze the amendments and reliance interests its own preamble identifies. Every deficiency above is documented in research the government paid for and the Forest Service largely produced. The Forest Service must adopt the No Action Alternative and preserve these roadless areas intact. Sources, all federally funded: https://www.fs.usda.gov/about-agency/features/fire-never-starts https://doi.org/10.1038/s41598-022-06002-3 https://doi.org/10.1073/pnas.2315797120 https://doi.org/10.1071/WF13158 https://doi.org/10.3390/f7100237 https://www.fs.usda.gov/pnw/pubs/pnw_gtr509.pdf https://www.fs.usda.gov/rm/pubs/rmrs_gtr042_6.pdf https://research.fs.usda.gov/treesearch/38282