Comment Analysis · Docket FS-2025-0001

FS-2025-0001-311327

Opposes rescissionA3 weakSubstance 5/24Owed an answerPosted September 3, 2026 On Regulations.gov

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 Evidence.

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

Forest Management Wildfire
- “vehement opposition to repealing the Roadless Area Conservation Rule”
- “USFS incorrectly asserts that repealing the roadless rule will allow for better wildfire mitigation”
- “highest designated wilderness areas had the lowest density of wildfire ignitions”
- “protected lands experienced LOWER fire severity”
Scientific Research Evidence
- “An analysis that reviewed three decades of wildfire data”
- “Another 2017 study which analyzed two decades of wildfire data”
- “A study that analyzed data from 1500 fires in the Western US”
- “real-world data that directly refutes this overly simplistic and ultimately incorrect hypothesis”

What it names

Works cited: 10.1002/ecs2.149210.1073/pnas.161739411410.1186/s42408-026-00450-2Balch et al. 2017

The comment

I am a nature lover and California resident who has lived in multiple areas that have been devastated by wildfires (Los Angeles and Napa Valley) and I am in vehement opposition to repealing the Roadless Area Conservation Rule. The USFS incorrectly asserts that repealing the roadless rule will allow for better wildfire mitigation. However, it has been repeatedly shown that land development and the subsequent presence of humans is by far the biggest cause of wildfires. An analysis that reviewed three decades of wildfire data found that the highest designated wilderness areas had the lowest density of wildfire ignitions, while lands within 50 m of roads had the highest wildfire ignition density. The study found that “for human-caused, natural, and undetermined fires, wildfire ignition density decreased as distance to road increased” (1). Another 2017 study which analyzed two decades of wildfire data found that a whopping 84% of wildfires were started by humans (2). Together, this evidence suggests that making these areas more accessible to humans is counterproductive to reducing wildfire risk. It is true that unmanaged lands have greater biomass and fuel loading, theoretically increasing the severity of fires in those areas. However, we have real-world data that directly refutes this overly simplistic and ultimately incorrect hypothesis. A study that analyzed data from 1500 fires in the Western US (which is exactly where lands protected by the roadless rule are located) over almost 40 years found that protected lands experienced LOWER fire severity, while those with “more intense management” experienced higher burn severity (3). While wildfires are indeed a serious and growing problem here in California, this misguided attempt to repeal the roadless act will only exacerbate this issue by making lands more vulnerable to wildfire ignitions, and less resilient to fires once they start. Citations: Aplet, G.H., Hartger, P. & Dietz, M.S. Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. fire ecol 22, 8 (2026). https://doi.org/10.1186/s42408-026-00450-2 J.K. Balch,B.A. Bradley,J.T. Abatzoglou,R.C. Nagy,E.J. Fusco, & A.L. Mahood, Human-started wildfires expand the fire niche across the United States, Proc. Natl. Acad. Sci. U.S.A. 114 (11) 2946-2951, https://doi.org/10.1073/pnas.1617394114 (2017). Bradley, C. M., C. T. Hanson, and D. A. DellaSala. 2016. Does increased forest protection correspond to higher fire severity in frequent-fire forests of the western United States? Ecosphere 7(10): e01492. 10.1002/ecs2.1492