In short: The comment establishes that the DEIS's conclusion that new roads have no material effect on wildfire ignition rates is unsupported and contradicted by its own data, specifically citing Tables 18 and 21 to show that human-caused ignition density is 7.5 times higher on non-roadless lands than in IRAs.
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
- Wildlife Habitat
- “destruction of treasured wildlife”
- “sight of a black bear family”
- “howling coyotes, rustling birds and scratching land mammals”
- “amazing moments found only on our protected lands”
- Forest Management Wildfire
- “80% of wildfires occuring closest to roads”
- “human caused ignitions increase in abundance with proximity to roads”
- “Road density is linked to human-caused wildfires”
- “jeopardize human life”
- Scientific Research Evidence
- “Unsupported and Uncited Conclusion”
- “contradicts the DEIS's own cited findings and its own data”
- “Table 18 (p. 95) reports all-cause ignition density”
- “Table 21 (p. 98) decomposes that figure by cause”
What it names
- 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: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequest