Comment Analysis · Docket FS-2025-0001

FS-2025-0001-345203

Opposes rescissionA2 moderateSubstance 13/24Owed an answerPosted September 12, 2026 On Regulations.gov

In short: The comment places on the record specific data from the DEIS (Tables 18 and 21) and external scientific literature demonstrating that road construction increases human-caused wildfire ignition rates and fragments habitat for the vulnerable Eastern Joshua Tree, arguing the DEIS fails to adequately evaluate these impacts in the Potosi Inventoried Roadless Area.

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

A2 moderate: Hard to dismiss — it shows cause and effect.

Owed an answer on Analytical gap.

Standard dismissals it defeats

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.

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.
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.
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

Recreation Tourism Public Use
- “outdoor enthusiast who has relied on the protection afforded by the 2001 Rule”
- “hiking on these lands, looking at plants, and rock climbing”
- “experience the great outdoors the traditional way - without man's interference”
- “lose valuable untouched wilderness to vehicle disturbance, air pollution, and noise pollution”
Environmental Protection Biodiversity
- “vulnerability of Eastern Joshua Tree (Yucca jaegeriana)”
- “Roads fragment intact habitat through cut-and-fill earthwork”
- “Grazing greatly reduced biodiversity and multifunctionality”
- “cutting them into patches of thinner areas, no good for the wildlife I want to see”
Forest Management Wildfire
- “human caused ignitions increase in abundance with proximity to roads”
- “Road density is linked to human-caused wildfires”
- “human-caused ignition density is 22.4 against 3.0”
- “DEIS's conclusion that new road construction will have no material effect on wildfire ignition rates... is stated without support”
Legal Regulatory Framework
- “proposed rescission inadequately grounded in any countervailing evidence”
- “A programmatic analysis is insufficient”
- “The DEIS must evaluate... at the scale of the Potosi Inventoried Roadless Area”
- “give full weight to the administrative record compiled over more than two decades”

What it names

National Forests: Humboldt-Toiyabe National Forest
Roadless areas: Potosi
Works cited: Balch et al. 2017Cardille et al. 2001Chen and Jin 2022Narayanaraj and Wimberly 2012Parisien et al. 2016

The comment

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

Dear Brooke L. Rollins, As an outdoor enthusiast who has relied on the protection afforded by the 2001 Rule to access interior national forest in a condition substantially unmodified by motorized infrastructure, I find the Department's proposed rescission inadequately grounded in any countervailing evidence of comparable public benefit. I spend time hiking on these lands, looking at plants, and rock climbing to escape the heat of the city. It is beautiful and full of life, and a precious resource for Americans to get outside in Nevada. I remember hiking and finding clumps of cacti among the older pines and junipers and wondering how long they have existed here. I would hope my children would be able to have these same thoughts and be in awe of these plants. If this rule is rescinded, I will lose valuable untouched wilderness to vehicle disturbance, air pollution, and noise pollution. I go to these areas because they have these rules in place, and I can experience the great outdoors the traditional way - without man’s interference. It will also cut through wilderness areas, cutting them into patches of thinner areas, no good for the wildlife I want to see. Regarding the Potosi Area in the Humboldt-Toiyabe National Forest, Nevada: Conservation status G3 reflects the vulnerability of Eastern Joshua Tree (Yucca jaegeriana) in the Potosi Inventoried Roadless Area, Humboldt-Toiyabe National Forest, where 7.1 - Fire & fire suppression acts at Serious or 31-70% pop. decline severity across Restricted - small scope. Roads fragment intact habitat through cut-and-fill earthwork, compact soils, reroute surface and subsurface water flow, and create impervious surfaces — each mechanism amplifying the effects of 7.1 - Fire & fire suppression on Eastern Joshua Tree. A programmatic analysis is insufficient. The DEIS must evaluate 7.1 - Fire & fire suppression impacts to Eastern Joshua Tree (Yucca jaegeriana, G3) at the scale of the Potosi Inventoried Roadless Area, Humboldt-Toiyabe National Forest, with specificity adequate to inform the decision. "Grazing by domestic herbivores is the most widespread land use on the planet, and also a major global change driver in grasslands. We show that aridity partly explains the responses of biodiversity and multifunctionality to long-term livestock grazing. Grazing greatly reduced biodiversity and multifunctionality in steppes with higher aridity, while having no effects in steppes with relatively lower aridity. Long-term grazing had no effects in meadow steppes with relatively lower aridity, but reduced biodiversity and multifunctionality in desert steppes with higher aridity." — Nature Communications, 2023 Regarding wildfires: The DEIS's conclusion that new road construction will have no material effect on wildfire ignition rates in inventoried roadless areas is stated without support and contradicts the DEIS's own cited findings and its own data. The DEIS establishes the mechanism itself. At p. 98 it states that "human caused ignitions increase in abundance with proximity to roads, supporting the notion that roads facilitate human access, which can in turn result in more human caused fires," citing Narayanaraj and Wimberly 2012, Parisien et al. 2016, Balch et al. 2017, and Chen and Jin 2022. At p. 109 it states that "[r]oad density is linked to human-caused wildfires, and as the density of roads increases so does the probability, number, and frequency of wildfire ignitions (Cardille et al. 2001)." Every one of these sources is in the DEIS's own bibliography. The DEIS also quantifies the differential, and the relevant figure is not the one most often quoted. Table 18 (p. 95) reports all-cause ignition density of 42 fires per million acres per year on other NFS lands against 12 in potentially affected IRAs. Table 21 (p. 98) decomposes that figure by cause: human-caused ignition density is 22.4 against 3.0 — a factor of 7.5 — while the natural-ignition rates are far closer at 16.8 against 8.5. The differential the DEIS attributes to roads is therefore the human-caused component, and it is more than twice the size the all-cause comparison suggests. The Department is urged to give full weight to the administrative record compiled over more than two decades before proceeding with any rescission action. Once the roads are plowed through America’s great wilderness, it cannot be undone. Faithfully, Ali Marie