Comment Analysis · Docket FS-2025-0001

FS-2025-0001-449040

Opposes rescissionA1 strongSubstance 15/24Owed an answerPosted September 21, 2026 On Regulations.gov

In short: The comment establishes that the Draft EIS's wildfire analysis fails to isolate road-proximity effects from confounders like biophysical differences and detection rates, and that Figure 15 lacks necessary documentation (data source, period, distance classes, ignition counts), thereby failing to provide a reasoned explanation for the asserted increase in wildfires under 5 U.S.C. § 706(2)(A) and 7 CFR 1b.11(a)(23).

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

Environmental Protection Biodiversity
- “protect watersheds”
- “promote biodiversity of fish, wildlife, and plant species”
- “value the over 40 million acres of roadless areas”
Forest Management Wildfire
- “Building roads into roadless areas is likely to result in more wildfires”
- “More roads = more people = more fires”
- “human caused ignitions increase in abundance with proximity to roads”
Legal Regulatory Framework
- “supplement the wildfire occurrence analysis (7 CFR 1b.7(f)(2)(iii))”
- “factual correction under 7 CFR 1b.7(f)(2)(v)”
- “not a reasoned explanation under 5 U.S.C. Sec. 706(2)(A)”
Recreation Tourism Public Use
- “avid user of the roadless areas”
- “provide irreplaceable recreational opportunities”

What it names

Law cited: 284 F.3d 1062 5 U.S.C. Sec. 706 7 CFR 1b 7 CFR 1b.11(a)(23)
Works cited: Narayanaraj and Wimberly 2012

The comment

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

Dear Secretary Rollins and Chief Shultz: I am writing as an avid user of the roadless areas not only in my home state of Idaho, but across the United States. Although Idaho may have its own roadless rule, I still value the over 40 million acres of roadless areas across all America's public lands. These areas are important to me because they exist to protect watersheds, promote biodiversity of fish, wildlife, and plant species, as well as provide irreplaceable recreational opportunities. With over 300,000 miles of existing roads on National Forests today that cannot be properly maintained, more roads by means of rescinding the Roadless Rule is exactly what the Forest Service should not be attempting to do. Building roads into roadless areas is likely to result in more wildfires. Roads will not stop nor lessen the increasing amount or frequency of wildfires. More roads = more people = more fires. In the Wildfire Occurrence section on page 98 of the Draft EIS, the agency states: "Consistent with other research findings, these analyses indicate 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 (Narayanaraj and Wimberly 2012, Parisien et al., 2016, Balch et al., 2017, Chen and Jin, 2022)." The Comparison of Alternatives table in Chapter 2 carries that finding into the effects comparison, stating that under alternatives 2 and 3, "if there is an increase in public road access, there could be an increase in the number and frequency of wildfires as human-ignitions are more likely near roads." The Draft EIS therefore treats an increase in the number and frequency of wildfires arising from road proximity as a reasonably foreseeable effect of the proposed action. The analysis presented in the Draft EIS does not support that finding at the magnitude asserted, for two reasons established by the document's own text. First, the two analyses of the Draft EIS documents measure land designation, not road distance. Table 18 (p. 95) and Table 21 (p. 98) both compare other NFS lands, potentially affected IRAs, and wilderness, using Interagency Fire Occurrence Reporting Module (InFORM) Fire Occurrence Data Record ignitions with a point of origin on NFS lands for 2014-2024. A contrast among land designations cannot isolate a road-proximity effect. It states that "Other NFS lands typically have more land management activities, infrastructure (such as powerlines), and public recreation that can lead to human caused ignitions," and it reports that other NFS lands have "about twice the density of natural ignitions than IRAs or wilderness, potentially due to biophysical differences or higher detection rates" (p. 98). Natural ignitions are not caused by road access. The agency's own explanation for the natural-ignition differential - biophysical difference and detection rate - applies equally to the human-ignition differential in Table 21, and the Draft EIS neither tests nor excludes it before attributing that differential to roads. Second, the only analysis in the Draft EIS that measures ignitions against road distance is Figure 15, "Density of reported ignitions by distance to roads and cause within the potentially affected IRAs" (p. 98). The Figure 15 caption identifies no data source and no period, and the figure carries none of the documentation supplied for those tables in footnotes 38 through 40 on page 94. The narrative does not reference Figure 15 or report any value from it - no distance classes, no ignition counts by cause, no exposed area, no densities. The one within-IRA road-distance analysis in the document is presented with none of the information a reader would need to evaluate it, while the two designation-level analyses that cannot answer the road-distance question are fully documented. I request that the Forest Service supplement the wildfire occurrence analysis (7 CFR 1b.7(f)(2)(iii)) to report the data underlying Figure 15 - the distance classes, ignition counts by cause, exposed area, and resulting ignition densities - and to state whether the road-distance relationship within the potentially affected IRAs survives the confounders the Draft EIS itself identifies on page 98. If it does not, the finding on page 98 and the Fire and Fuels row of the Comparison of Alternatives require factual correction under 7 CFR 1b.7(f)(2)(v). Absent one or the other, the Final EIS would assert a reasonably foreseeable effect for which it has disclosed no supporting analysis: not a cause-effect relationship established within the meaning of 7 CFR 1b.11(a)(23), and not a reasoned explanation under 5 U.S.C. Sec. 706(2)(A). See Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002). This concern is directed to both the Draft EIS and the proposed rule. An answer given only in the Final EIS response-to-comments appendix would leave the concern unanswered as a comment on the rule.