Comment Analysis · Docket FS-2025-0001

FS-2025-0001-342254

Opposes rescissionA1 strongSubstance 17/24Owed an answerPosted September 9, 2026 On Regulations.gov

In short: The comment establishes that the Draft EIS fails to reconcile its admission that road access correlates with human-caused ignitions with the rationale for expanding road access, citing specific data on ignition density and WUI acreage discrepancies to demonstrate the inadequacy of the agency's analysis.

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
- “personally put out at least 5 human-caused fires that were started on or near a road”
- “ignition density near roads reaching 7.99 fires/1000 ha versus 1.97 fires/1000 ha in Inventoried Roadless Areas”
- “The argument that rescission is needed for more fuels management and is false”
- “if a fire starts off a newly built road because Alternative 2 or 3 was approved”
Recreation Tourism Public Use
- “I have skied, backpacked, hiked, biked and driven throughout multiple national forests”
- “frequently recreate there as a OHV trail user with my Jeep”
- “comments advocating for no change to the roadless rule from all different types of public land owners (hunters, anglers, OHV'ers, hikers, and others)”
Legal Regulatory Framework
- “Under Blue Mountains Biodiversity Project v. Blackwood... the agency must confront contrary evidence rather than ignore it”
- “I request the agency cite its ignition-density source and add explicit reconciliation analysis”
- “The Draft EIS states that... the agency's own admission that road access correlates with human-caused ignition is never reconciled”

What it names

National Forests: Los Padres National Forest
Law cited: 161 F.3d 1208 161 F.3d 1208 872 F.2d 497 872 F.2d 497
Works cited: Healey 2020Healey 2020

The comment

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

Roadless Rule Comment—FS-2025-0001-223869 My family and I have had a concession on USFS lands since 1917. I grew up literally living on USFS land in the summers, and directly adjacent to National Forest in the Lake Tahoe Basin in the winters. I have skied, backpacked, hiked, biked and driven throughout multiple national forests in our country. Additionally, I own property adjacent to the Los Padres National Forest and frequently recreate there as a OHV trail user with my Jeep. I am writing to urge you to support Alternative 1, no change. I am disturbed and appalled that despite receiving over 600,000 comments advocating for no change to the roadless rule from all different types of public land owners (hunters, anglers, OHV’ers, hikers, and others), the USFS has prepared an EIS recommending rescinding the rule, and states that this is largely to better manage wildfire. Over the last 50 years of living on the National Forest and managing recreational use, I personally have experienced both the 2007 Angora Fire and the 2021 Caldor Fire in Lake Tahoe. I have also personally put out at least 5 human-caused fires that were started on or near a road. I’ve also seen the ineffectiveness of roads and bulldozed lines as large fires in CA such as the 2025 Gifford, 2021 Caldor and 2018 Carr fire jumped lines and roads multiple times. The Draft EIS states that "the number, frequency, and density of wildfire ignitions are lower in designated wilderness and potentially affected Inventories Roadless Areas compared to other NFS lands" and acknowledges that "if there is an increase in public road access, there could be increase the number and frequency of wildfires as human-ignitions are more likely near roads" (Comparison of Alternatives, pp. 20-36). This ignition-density comparison is uncited, and the agency's own admission that road access correlates with human-caused ignition is never reconciled with any fire-risk rationale for expanding road access under Alternatives 2 and 3. A peer-reviewed three-decade national forest fire record found ignition density near roads reaching 7.99 fires/1000 ha versus 1.97 fires/1000 ha in Inventoried Roadless Areas — evidence squarely on point that the agency should engage. Under Blue Mountains Biodiversity Project v. Blackwood, 161 F.3d 1208 (9th Cir. 1998), and Sierra Club v. Marsh, 872 F.2d 497 (1st Cir. 1989), the agency must confront contrary evidence rather than ignore it. I request the agency cite its ignition-density source and add explicit reconciliation analysis before finalizing this document. In addition, Forest Service Chief Tom Schultz recently testified to the Senate that 24.5 million acres of inventoried roadless areas are within one mile of the Wildland-Urban Interface (WUI)—calling it "our primary concern." A GIS analysis by The Wilderness Society using the Forest Service's own data found the actual figure is just 2.8 million acres—a nearly ninefold exaggeration. Less than 5% of inventoried roadless area acreage is in close proximity to the WUI, not 42% as Schultz claimed. The administration has 23.3 million acres of non-roadless forest land already available near the WUI for fuel reduction—without ever touching a roadless area. The argument that rescission is needed for more fuels management and is false. The current roadless rules allows for fuels management under certain circumstances, including to reduce fuel loads in the wildland-urban interface and to improve habitat for threatened, endangered, or sensitive species. This already has been done in multiple roadless areas in the Tahoe Basin. The Forest Service’s own research shows that roadless areas have historically received a larger proportion of fuels management projects than other areas of the National Forest System. (Sean P. Healy, Long-term forest health implications of roadlessness, Environmental Research Letters. September 2020. https://doi.org/10.1088/1748-9326/aba031). As a property owner and business owner near wildfire-prone areas in two parts of California, your decision impacts me personally and professionally if a fire starts off a newly built road because Alternative 2 or 3 was approved. I could lose my home and my business. Please choose Alternative 1. Thank you for considering my comment.